NC0089699_Application_20181130

Please print or type in the unshaded areas only.
Form Approved. OMB No. 2040-0086.
FORM
U.S. ENVIRONMENTAL PROTECTION AGENCY
I. EPA I.D. NUMBER
S
A C
110000346849
1
\-EPA GENERAL INFORMATION
F
Consolidated Permits Program
p
L
GENERAL
(Read the "General Instructions" before starting.)
,
z ,a ,a 1s
LABEL ITEMS
GENERAL INSTRUCTIONS
If a preprinted label has been provided, affix it in the
designated space. Review the information carefully; if any of it
I. EPA I.D. NUMBER
is incorrect, cross through it and enter the correct data in the
appropriate fill-in area below. Also, if any of the preprinted data
is absent (the area to the left of the label space lists the
III. FACILITY NAME PLEASE PLACE LABEL IN THIS SPACE information that should appear), please provide it in the proper
fill-in area(s) below. If the label is complete and correct, you
V. FACILITY MAILING
need not complete Items I, III, V, and VI (except VI-B which
ADDRESS
must be completed regardless). Complete all items if no label
has been provided. Refer to the instructions for detailed item
VI. FACILITY LOCATION
descriptions and for the legal authorizations under which this
data is collected.
II. POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to determine whether you need to submit any permit application forms to the EPA. If you answer "yes" to any questions, you must
submit this form and the supplemental form listed in the parenthesis following the question. Mark "X" in the box in the third column if the supplemental form is attached. If
you answer "no" to each question, you need not submit any of these forms. You may answer "no" if your activity is excluded from permit requirements; see Section C of the
instructions. See also, Section D of the instructions for definitions of bold-faced terms.
Mark "X"
Mark "X"
YES
NO
FORM
ATTACHED
YES
No
FORM
ATTACHED
SPECIFIC QUESTIONS
SPECIFIC QUESTIONS
A. Is this facility a publicly owned treatment works which
B. Does or will this facility (either existing or proposed)
results in a discharge to waters of the U.S.? (FORM 2A)
X
include a concentrated animal feeding operation or
X
aquatic animal production facility which results in a
16
17
18
19
20
21
discharge to waters of the U.S.? (FORM 2B)
C. Is this a facility which currently results in discharges to
waters of the U.S. other than those described in A or B
�/
X
D. Is this a proposed facility (other than those described in A
or B above) which will result in a discharge to waters of
X
X
above? (FORM 2C)
the U.S.? (FORM 2D)
zz
2a
z4
zs
26
27
E. Does or will this facility treat, store, or dispose of
F. Do you or will you inject at this facility industrial or
hazardous wastes? (FORM 3)
X
municipal effluent below the lowermost stratum
X
containing, within one quarter mile of the well bore,
underground sources of drinking water? (FORM 4)
28
29
30
31
32
33
G. Do you or will you inject at this facility any produced water
H. Do you or will you inject at this facility fluids for special
or other fluids which are brought to the surface in
processes such as mining of sulfur by the Frasch process,
connection with conventional oil or natural gas production,
X
solution mining of minerals, in situ combustion of fossil
X
inject fluids used for enhanced recovery of oil or natural
fuel, or recovery of geothermal energy? (FORM 4)
gas, or inject fluids for storage of liquid hydrocarbons?
(FORM 4)
34
35
36
37
1 39
39
I. Is this facility a proposed stationary source which is one
J. Is this facility a proposed stationary source which is
of the 28 industrial categories listed in the instructions and
�/
X
NOT one of the 28 industrial categories listed in the
X
which will potentially emit 100 tons per year of any air
instructions and which will potentially emit 250 tons per
pollutant regulated under the Clean Air Act and may affect
year of any air pollutant regulated under the Clean Air Act
40
41
42
43
44
45
or be located in an attainment area? (FORM 5)
and may affect or be located in an attainment area?
(FORM 5)
III. NAME OF FACILITY
c
1 SKIP Novozymes North America, Inc
15
i6 - 29
30
69
IV. FACILITY CONTACT
A. NAME & TITLE (last, first, & title)
B. PHONE (area code & no.)
J2c
Walsh, Angela, Mgr- Environmenta & Utilities Operations ( 1 ) 4 4-3 0
is
16
45 46 48 49 51 1 52- 55
V. FACILTY MAILING ADDRESS
A. STREET OR P.O. BOX
c
3 JPO Box 56
s 16
45
B. CITY OR TOWN
C. STATE D. ZIP CODE
Jc
4 Frank inton
15 16
C 2 5 5
40 41 42 47 51
VI. FACILITY LOCATION
A. STREET, ROUTE NO. OR OTHER SPECIFIC IDENTIFIER
J5C 7 Perrys C apel Church Road
5 16
45
B. COUNTY NAME
Franklin
46
70
C. CITY OR TOWN
D. STATE
I E. ZIP CODE
F. COUNTY CODE (if known)
c
6
Frank inton
C
2 5 5 1
5
15
16
40
41 42
47 51
52 -54
EPA Form 3510-1 (8-90) CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
Vii. sib cobE5 4-di it, in order of ' rff
A. FIRST B. SECOND
c CP fY) si
s eii
7' 28i]'� industrial prgani�c Chemicals G 7 (Pec.�y)
15 ' 16 '19 75 16 19
C. THIRD D. FOURTH
� {spec%fYJ c (Sp�Cf
7 7
ss 16 19 15 16 f9
VIII. OPERATOR INFORMATIQN
c
A- NAME B.Is the name llsted in Item
VIII-A also. the:ownerl
s Novo.zymes North. America Inc. YES Q NO
f5. 56 55 66
C, STATUS OF OPERATOR (rnler rile appropriate letter into rite anwer bar if " 01her, "sjieciffy.} D. PHONE (area code r(no)
E = FEDERAL (specify)
S=STATE M-PUBLIC(urherrhanfirlcralorsrmeJ �] A �91g] 494-3.00fl
qT
P = PRIMATE O = OTHER (5pegry).
`� 15 '1B 19 21 26
E', STREET OR P.p, BOX
77:Perrys Chapel. C urch Roa'
F. CITY OR TOWN G. STATE H- —ZIP CODE Ix, INDIAN LAND
c
B Fxanlcl triton Is.the facility located on Indian lands?
NC 27525 ❑ YES. ONO
15 1e 40 51 42 47 - 51
X. EXISTING ENVIRONMENTAL PERMITS
A. NPDE5 Dlydla e3la.Su ure iYarer D. PSD Air r3missionsfromF sed.5urrrceS
c r c r
s N NCG5bons 9 P
151 18 1 17 15 3Q 151 16 1 17 1 1a
B. UIC Chide •ronji d lnlecrr vo-laid. E. OTHER s ec'f s
c r C 'T I E
w o j 0 2 a o s [y cri y)
9 V 9 Wastowater Srrigat oli System. Permit:
16 i? 1fl 3v715 16 1 17 lie
C. RCIRA Haiardaus IYasres E_ OTHER s ecr •
{S�ecefyj
9 R 9. 1UP40 1 1 2 Snduatrial.User Pretreatment Permit
i5 1 16 1
7 18 3a75 16 17 18
XI- MAP
Attach to this application a topographic map'of the. area extending to at least one mile beyond property boundaries. The map must: show the outline of the. Facility, the.
location of each of Its existing and proposed intake..and discharge structures, each of its hazardous waste treatment, storage, or disposal. facilities, and each well where it
injects fluids: unde.rground. Include all springs, rivers, and other surface water bodies in the map area. See instructions for precise requirements.
XII. NATURE OF BUSINESS (provide a bnefdesori ion
.At Nov.ozymes, industrial enzymes are produced using a process called submerged ferineritatiori This involves
growing carefully se3ected.mczaoganissns (bacteria and fungi} inclosed vessels containing a rich broth of
nutrients. As the microorganisms. break dawn the nutrients, they produce t'hedesired. enzymes, .The 'fermentat an
process requires nutrients based on.renewable'raw 'materials. li.'ke corn starch, sugars, and soy .grits, The first
step. in harvesting enzyme s:from the 'fermentation medium is. to remove insoluble produ..cts, prmarzly microbial
cell§.. This is normally done by centrifugation or micrv£iltrat:ion steps. As.:most industrial enzymes. are
extracellul'ar ---'secreted. by cells into the .external environment - they remain in the fermented broth after the
biomass. has been 'removed. The. biomass :can be recycled .as a fertilizer vn 'local farms; as. is done under .a
residuals disppsa] permit at.NoVozymes' Pranklinton site. The enzymes in the rernainizig"broth. are Chen
concentrated by.evaporation', membrane filtration or crystallization depending on .their iTntended application,
Certain applications requalre solid enzyme products, so the crude enzyme is preceesed into a granulate for
convenient dust -free use.
XIII. CERTIFICATION {see iRsfrucflons}
1.certify under penally of law that 1 have personally exam)Red and am familiar with the information submitted in. this application and all attachments and that,. based on my
inquiry of thosai persons immediately. responsible for obtaining the information contained in the application, 1.believe that the information.fs true, accurate; and compiefe. l
Am aware thatih ere are'sr"gnificanf penaltfas:for submitting false. information, including the possibfidy of fine. and imprisonment.
A. NAME &•OFFlit IAL TITLE (type orprint) B.. SIGNATURE C. DATE SIGNED
Adam Monroe, President
COMMENTS FOR OFFICIAL USE ONLY
C
C
15 1B
EPA Farm 35.10=1 (8-90)

Dewberry"
Best Available Technology
(BAT) Economically
Achievable Analysis
NPDES Discharge Permit to Cedar Creek
Novozymes, North America, Inc.
SUBMITTED BY:
Dewberry
2610 Wycliff Road
Suite 410
Raleigh, NC 27607
PREPARED FOR:
Novozymes
North America, Inc.
SUBMITTED TO:
NCDEQ

TABLE OF CONTENTS
TABLE OF CONTENTS..................................................................................................1
LISTOF ACRONYMS.....................................................................................................4
1. INTRODUCTION...................................................................................................... 5
2. INDUSTRIAL PROCESS DESCRIPTION................................................................7
2.1 Facility Description....................................................................................................................7
2.2 Wastewater Treatment and Discharge Permits....................................................................... 7
3. NOVOZYMES' CURRENT WASTEWATER TREATMENT.....................................9
3.1 Influent Wastewater Characteristics.........................................................................................9
3.2 2010 — 2014 WWTP Operation.................................................................................................9
3.3 2015 to Present WWTP Operation..........................................................................................10
3.4 Historical WWTP Performance................................................................................................11
4. TREATMENT TECHNOLOGY ALTERNATIVES EVALUATED ............................13
4.1 Treatment Technologies..........................................................................................................13
5. Treatability Testing...............................................................................................14
5.1 Treatability Testing Approach.................................................................................................14
5.2 Treatability Testing Protocol...................................................................................................15
5.3 Performance Testing Results...................................................................................................16
6. PROPOSED PROCESS TREATMENT DESCRIPTION........................................19
6.1 Primary Clarification...............................................................................................................19
6.2 Bioreactors.............................................................................................................................. 20
6.3 Aeration Equipment............................................................................................................... 20
6.4 Secondary Clarification........................................................................................................... 20
6.5 Dissolved Air Flotation(DAF)................................................................................................. 21
6.6 Ultra -Filtration (UF)/Reverse Osmosis (RO) System........................................................... 21
7. BIOLOGICAL PROCESS MODELING.................................................................. 22
8. EQUIVALENT ANNUAL COST ANALYSIS.......................................................... 24
9. BAT LIMIT DETERMINATION............................................................................... 26
9.1 Total Nitrogen BAT Limits......................................................................................................26
9.2 Total Phosphorus BAT Limits................................................................................................ 30
10. CONCLUSIONS..................................................................................................... 32
Novozymes North America, Inc. I Best Available Technology Analysis 11
11:�_� Dewberry-

LIST OF TABLES
Table 2.1 Industrial User Pretreatment Permit Limits
Table 3.1 Novozymes' Influent Wastewater Characteristics
Table 3.2 Novozymes' Historical Effluent Wastewater Comparison
Table 3.3 Historical IUP Limits
Table 5.1 Treatability Testing Nitrogen Speciation Parameters
Table 5.2 Calculated Variability between Measured Internal Process and Certified Lab Data
Table 5.3 Treatability Testing 95th Percentile and Maximum Reactor Effluent Results
Table 6.1 Novozymes' Influent Wastewater Average Conditions to SND Activated Sludge Process
Table 7.1 Biowin© Kinetic Values
Table 7.2 Biowin® Effluent Nitrogen Results
Table 7.3 Modeled and Estimated Effluent Nitrogen Conditions
Table 8.1 Equivalent Annual Costs Comparison
Table 9.1 Calculated Effluent Total Nitrogen BAT Limits
Table 9.2 Equivalent Annual Costs Normalized to Nitrogen Removed
Table 9.3 Incremental TN Removal Cost Comparison
Table 9.4 Proposed Total Nitrogen BAT Limit
Table 9.5 North Carolina Municipal Total Nitrogen Surcharge Rates
Table 9.6 Proposed Phosphorus BAT Limit
Table io.1 Summary of Equivalent Annual Costs Normalized to Nitrogen Removed
Table 10.2 Proposed TN and TP BAT Limits
LIST OF FIGURES
Figure 1 2010 - 2014 Wastewater Treatment Configuration
Figure 2 Current Wastewater Treatment Configuration
Figure 3 Biowin© Model Diagram
Figure 4 TN Effluent Results Comparison
Figure 5 Normalized Nitrogen Removal Costs
Figure 6 Effluent Phosphorus Concentrations vs. Metal Coagulant to Phosphorus Dose
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 12

APPENDICES
Appendix A Wastewater Irrigation System Permit (Permit # WQ00028o6)
Appendix B Industrial User Pretreatment Permit (Permit # 0112)
Appendix C Approved Corrective Action Plan Correspondence
Appendix D DEQ December 14, 2016 BAT Correspondence Letter
Appendix E Novozymes September 7, 2o18 Correspondence to the Division
Appendix F Novozymes' WWTP Existing Site Layout
Appendix G Novozymes' 2oio — 2014 Historical Wastewater Effluent Data
Appendix H Novozymes' 2oi5 — 2018 Historical Wastewater Effluent Data
Appendix I Certified Lab Data
Appendix J Dewberry Treatability Reactor Logs
Appendix K Proposed Novozymes Wastewater Treatment Plant Upgrades Block Flow Diagram
Appendix L Preliminary Equipment Specification Table
Appendix M Biowin© Model Inputs and Outputs
Appendix N Capital and Recurring Cost Estimates
Appendix O Vendor Quotes
,�" Dewberry
North America, Inc. Best Available Technology Analysis 3

LIST OF ACRONYMS
ADF
Average daily flow rate
BAT
Best Available Technology
BFD
Block flow diagram
BOD
Biological oxygen demand
CEAM
Center for Exposure Assessment
Modeling
COD
Chemical oxygen demand
C.F.R
Code of Federal Regulations
DAF
Dissolved air floatation
DO
Dissolved oxygen
EAA
Engineering alternatives analysis
EPA
Environmental Protection Agency
gpd
gallons per day
gpm
gallons per minute
HWA
Headworks Analysis
IUP
Industrial user permit
lb/d
pound per day
lb/wk
pounds per week
MGD
Million gallons per day
mg/L
milligrams per liter
MLVSS Mixed liquor volatile suspended solids
NCDEQNorth Carolina Department of
Environmental Quality
NH3-N Ammonia measured as nitrogen
NPDES National Pollution Discharge
Elimination System
NSW Nutrient sensitive waters
POTW Publicly owned treatment works
PVCA Present value cost analysis
RAS Return activated sludge
RO Reverse osmosis
s.u. standard units (pH)
SND Simultaneous nitrification and
denitrification
TDS total dissolved solids
TP total phosphorus
TSS total suspended solids
TKN total Kjeldahl nitrogen
TN total nitrogen
USGS United States Geological Survey
WAS Waste activated sludge
WWTP Wastewater Treatment Plant
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 14

1. INTRODUCTION
Novozymes North America, Inc. (Novozymes) has applied for a National Pollutant Discharge Elimination System
(NPDES) permit for direct discharge of wastewater from its manufacturing facility located in Franklinton, North
Carolina. Novozymes is seeking a NPDES discharge to Cedar Creek, a tributary to the Tar River located in the Tar -
Pamlico River Basin. Currently, Novozymes discharges all process wastewater from the facility by one of two
methods: (1) land application on agricultural fields pursuant to Non -Discharge Permit (WQ00028o6) (Appendix A),
and (2) indirect discharge to the Franklin County Wastewater Treatment Plant (WWTP) pursuant to Industrial User
Pretreatment (IUP) Permit 0112 (Appendix B).
Novozymes applied for the NPDES permit to comply with the provisions of the Corrective Action Plan for the North
Carolina Department of Environmental Quality (NCDEQ) Division of Water Quality (Division) Incident Number
86545 that was conditionally approved by the Division Director on January 31, 2017 (Appendix C). Per the
requirements of the approved Corrective Action Plan, Novozymes must reduce land application rates of treated
wastewater from 30 inches/yr to 8.5 inches per year and also must recover and treat approximately go,000 gpd of
groundwater. The Division's approval of the Corrective Action Plan requires Novozymes to obtain the NPDES permit
to satisfy these requirements (Appendix C). Additionally, the NPDES permit will allow Novozymes to establish a fully
conjunctive wastewater system and increase operational flexibility by giving it three methods for disposing of
wastewater: (1) land application on nearby farm fields, (2) discharge to the Franklin County WWTP, and (3) direct
discharge to surface water. Last, Novozymes would like to expand the facility, increase production capacity, and add
manufacturing jobs in a rural community. Expansion of the facility will require significant additional discharge
capacity that would be provided by the NPDES permit.
A revised NPDES permit application, which included an updated Engineering Alternatives Analysis (EAA), was
submitted to the North Carolina Division of Environmental Quality (DEQ) Division of Water Resources (Division) on
11/3o/18. The NPDES application requested tiered flow limits for i.o,1.5 and 2.0 million gallons per day (MGD).
Cedar Creek is located in the Tar -Pamlico River Basin and is classified as a nutrient sensitive water (NSW) pursuant
to North Carolina Administrative Code Section i5A NCAC 02B.0223. Due to the discharge location is in the Tar -
Pamlico River Basin and as discussed in correspondence from the Division dated December 14, 201.6 (Appendix D),
the Division requested that Novozymes prepare and submit a Best Available Technology Economically Achievable
(BAT) analysis to assist in establishing permit limits for total phosphorus (TP) and total nitrogen (TN). The following
report presents that BAT analysis and proposes permit limits for TP and TN based on treatability testing, available
treatment technology, and equivalent annual costs. BAT Economically Achievable limits represent, in general, the
best existing performance of treatment technologies that are economically achievable within an industrial point
source category. (See EPA NPDES Permit Writers' Manual, 20io, EPA-833-K-io-ooi). The BAT analysis described
below was conducted pursuant to the protocol specifically agreed upon with the Division and as outlined in
correspondence dated September 7, 2018 (Appendix E).
To establish and support proposed BAT TN limits for the proposed Novozymes NPDES permit, three (3) treatment
technologies were evaluated based on treatability testing, and the capital and annual recurring operational costs to
remove nitrogen were compared amongst each technology evaluated.
A review of historical operating and technology performance data was performed to establish and support the BAT TP
limit for the proposed Novozymes NPDES permit.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 15

Along with the final determination, the following information is contained herein to provide the Division with the
BAT Analysis:
Industrial process description,
• Wastewater characterization,
• Wastewater treatability testing,
Proposed wastewater treatment processes, and
Cost Analysis
Dewberry, Novozymes North America, Inc. I Best Available Technology Analysis 16

2. INDUSTRIAL PROCESS DESCRIPTION
2.1 Facility Description
At Novozymes, industrial enzymes are produced using a process called submerged fermentation. This involves
growing carefully selected microorganisms (bacteria and fungi) in closed vessels containing a rich broth of nutrients.
As the microorganisms break down the nutrients, they produce the desired enzymes. The fermentation process
requires nutrients based on renewable raw materials like corn starch, sugars, and soy grits.
The first step in harvesting enzymes from fermentation medium is to remove insoluble products, primarily microbial
cells. This is normally done by centrifugation or microfiltration steps. As most industrial enzymes are extracellular —
secreted by cells into the external environment — they remain in the fermented broth after the biomass has been
removed. The spent biomass can be recycled as a fertilizer on local farms, as is done under a residuals disposal permit
at Novozymes' Franklinton site. The enzymes in the remaining broth are then concentrated by evaporation,
membrane filtration or crystallization depending on their intended application. Certain applications require solid
enzyme products, so the crude enzyme is processed into granules for convenient dust -free use. The wastewater
discharge at Novozymes consists of discharge from the fermentation and recovery production processes and from site
utilities such as cooling tower and boiler blowdown. From the facility, the waste streams are characterized into two
groups: permeate (e.g. filtrate produced from the membrane filtration step) and non -permeate (e.g. all other waste
streams). Both the permeate and non -permeate waste streams are treated onsite at the Franklinton facility at
Novozymes' WWTP.
Based on Novozymes' SIC Code 2869, the facility's industrial discharge is regulated under the Organic Chemicals,
Plastics, and Synthetic Fibers (OCPSF) effluent limits for Subcategory G Bulk Organic Chemicals (40 CFR 414.70).
However, Novozymes' manufacturing process is a fermentation process, and 40 CFR 414.1i(e) states the provisions of
40 CFR 414 do not apply to discharges from the manufacture of organic chemical compounds solely by fermentation
processes. It should be noted that even if the provisions of 40 CFR 414 did apply to the Novozymes facility, BAT
limits are not established in 40 CFR 414 Subcategory G for nitrogen.
2.2 Wastewater Treatment and Discharge Permits
Novozymes employs onsite wastewater treatment prior to discharge. Over the past decade, Novozymes has
historically operated its treatment facility in two different modes of operation. From 2010-2014, Novozymes used a
multi -stage activated sludge process consisting of moving bed biological reactors (MBBRs) with high chemical oxygen
demand (COD) loading followed by an extended aeration lagoon for COD removal, nitrification and denitrification
(see Section 3, Figure 1). The extended aeration system used was the Biolac® lagoon aeration system that provides
automatic dissolved oxygen and aeration control to create multiple oxic and anoxic zones in a single treatment basin,
eliminating the need for separate anoxic mixers and MLSS recycle flow and pumps.
In 2015, Novozymes installed an anaerobic treatment system upstream of the MBBRs (See Section 3, Figure 2). The
primary project driver was to improve sustainability metrics at the wastewater plant by reducing energy consumption
and sludge generation. This process modification resulted in a reduced capacity to treat nitrogen compared to the
previous configuration, but also reduced the amount of biosolids produced. The MBBRs were converted to
nitrification and denitrification polishing tanks with supplemental carbon addition. The existing Biolac lagoon
system is still utilized when additional COD reduction or nitrification is required. For reference, a more detailed
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 17

discussion of the existing treatment system configuration is provided in Section 3 below, and an existing WWTP site
layout is presented in Appendix F.
Novozymes currently discharges treated wastewater via two discharge permits: (1) land application through Non -
Discharge Permit (WQ00028o6), and (2) indirect discharge to the Franklin County WWTP via IUP Permit 0112. IUP
Permit 0112 was issued by Franklin County, effective November 14, 2018. The table below summarizes the effluent
parameters listed in the IUP with numerical limits.
Table 2.1. Industrial User Pretreatment Permit Limits
_M In IUP Permit
Parameter Limit
Flow MGD 0.525
Biochemical Oxygen Demand (BOD)
mg/L
100
Total Suspended Solids (TSS)
mg/L
150
Ammonia-N(NH3)m
/L
10.0
Total Nitrogen (TN)
Ibs/ month
1,825
Total Phosphorus TP
Ibs/ month
295
Potassium
Ibs/ month
65,956
Sodium
Ibs/month
50,608
Temperature
°C
40.0
pH
S.U.
6 - 10
Turbidity
NTU
15
Antimony
m /I
1.0
Cadmium
mg/I
0.008
Chromium
m /I
0.020
Copper
m /I
0.05
Cyanide
m /I
0.010
Lead
mg/I
0.0125
Nickel
m /I
0.0313
Zinc
m /I
0.390
Novozymes has also been re -issued a Non -Discharge Wastewater Irrigation System Permit by the Division, effective
date of June 8, 2017 for land application of 30 inches per year. Novozymes prepared a Corrective Action Plan
conditionally approved by the Division on January 31, 2017 (Appendix C) requiring Novozymes to reduce its land
application rate from 30 in/yr to 8.5 in/yr after the receipt of a NPDES permit and after construction and
commissioning of their upgraded treatment process and approved NPDES discharge.
The Corrective Action Plan as approved by the Division requires the NPDES discharge permit. The NPDES permit
will allow Novozymes to establish a fully conjunctive wastewater system and increase operational flexibility by giving
it three methods for disposing of wastewater: (1) land application on nearby farm fields, (2) discharge to the Franklin
County WWTP, and (3) direct discharge to surface water. Last, Novozymes would like to expand the facility, increase
production capacity, and add manufacturing jobs in a rural community. Expansion of the facility will require
significant additional discharge capacity that would be provided by the NPDES permit
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 18

3. NOVOZYMES' CURRENT WASTEWATER TREATMENT
3.1 Influent Wastewater Characteristics
The table below summarizes Novozymes' influent wastewater characteristics. The concentrations are based on
historical average influent data and are expected to be representative of future wastewater characteristics. As such,
these concentrations are utilized as the influent design criteria for the BAT analysis.
Table 3.1 Novozymes' Historical Influent Wastewater Characteristics
Parameter
Chemical Oxygen Demand COD
Design
Concentrations
(mg/1)
5,389
Ammonia-N(NH3)63
Total K'ehldahl Nitrogen TKN
197
Nitrate-N NO3
29
Total Nitrogen TN
208
Total Phosphorus TP
90
Sulfate
118
3.2 2010 — 2014 WWTP Operation
From 2010-2014, the Novozymes WWTP configuration (Figure 1) included a primary clarifier, followed by biological
treatment, clarification, and dissolved air floatation (DAF) for phosphorous removal. The primary clarifier is 35-ft in
diameter, and treats non -permeate based waste streams for solids and grit removal. Biological treatment for organics
and nitrogen was accomplished in two 240,000 gallon aerobic reactors (To2 and Toi), which operated in series as
MBBRs. Effluent from Toi was discharged to an in -ground treatment lagoon with an effective volume of 1.94 million
gallons (MG). The lagoon was equipped with a Biolac® aeration system. An internal recycle pump station was used
to recycle nitrate from the effluent end of the lagoon to the influent end. The Biolac® system was cycled on/off via
timers to create anoxic "zones".
Sludge was returned from the secondary clarifier to both the lagoon anoxic reactor zone and T02. Clarifier effluent
was either discharged to the effluent storage system prior to land application or to the DAF system for phosphorous
removal prior to discharge to the Franklin County WWTP. Novozymes has a 52 MG effluent storage lagoon located
onsite for land application.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 19

Primary
Clarifier
T02 "'
Aerobic Aerobic Anoxic Aerobic
Lagoon
Sludge Return
Figure 1. 2010 - 2014 Wastewater Treatment Configuration
Effluent
Storage
-Ill To Land Application
Secondary
Clarifier
Dissolved Air
Flotation
Lill ----- I ------- ► To Franklin County
Historical data from this period is provided in Appendix G and is summarized by monthly averages for flow, COD,
VSS, nitrate/nitrite (NO3/NO2), ammonia (NH3), total Kjehldahl nitrogen (TKN), and total suspended solids (TSS)
parameters.
The lagoon configuration presented some process challenges. For example, the mixed liquor biomass exhibited
tendency to settle within the lagoon when the Biolac® laterals were cycled off resulting in mass transfer limitations
and reduced treatment capacity within the anoxic zone. Furthermore, the lagoon is shallow (<io feet) and the oxygen
requirements often exceeded the supply capacity of the Biolac® system. These low DO conditions impacted the rate
of nitrification.
3.3 2015 to Present WWTP Operation
Novozymes currently operates under the treatment configuration depicted in Figure 2 below. As previously stated
above, the addition of the anaerobic treatment system reduced WWTP energy consumption and sludge generation,
but also reduced the capacity of the WWTP to remove nitrogen compounds. A summary of historical Novozymes
effluent data from January 2015 to October 2018 is presented in Appendix H. The data listed in Appendix H was
calculated from historical monthly data after tertiary (DAF) treatment.
----------------------
Anaerobic Svstem
i
Anaerobic
Primary
Clarifier Pre Reactor
Acidifiication i T02
Tank ' Aerobic
i
i
I To
Anoxic/
Aerobic I
ISludge Return
internal Nitrate Recycl
L_
i Anoxic Aerobic '
i
Lagoon
i
Used as needed _ _ _ _ ,
Figure 2. Current Wastewater Treatment Configuration
Effluent
Storage
To Land
Secondary Application
Clarifier
Dissolved Air
Flotation
\ To Frankin
County
Novozymes North America, Inc. I Best Available Technology Analysis 110
......*','Dewberry,

3.4 Historical WWTP Performance
Table 3.2 provides a summary of Novozymes' WWTP effluent operating data from the 2010-2018 historical data set
provided as Appendices G and H. The table lists the calculated average and maximum monthly average effluent
concentrations from reported daily and monthly data contained in the historical data set for COD, TP, TN, TKN, NH3
and NO3/NO2. The values are separated into two sections: before the implementation of the anaerobic system (2oio-
2014) and after the anaerobic system was brought online (2015-2018).
Table 3.2. Novozymes' Historical Effluent Wastewater Comparison'
Parameter
I Units
January 10 —
Average Monthly
Concentration
I (mg/1)
December 2014
Maximum Monthly
Concentration
(mg/1)
January 2015 — October
Average Monthly Maximum
Concentration
(mg/1)
2018
Monthly
Concentration
(mg/1)
"Data presented in this table represents the average and maximum of average monthly effluent values from Novozymes effluent data
shown in Appendices G and H.
For the period of 2010-2014, the TN and TP effluent concentrations discharged from the Novozymes' WWTP
averaged 15 mg/l and 2.2 mg/l respectively. For the most recent period following installation of the anaerobic system
(2015 — 2018), effluent TN concentration increased to 19 mg/L, and the effluent TP concentration decreased to 1.4
mg/l. It should be noted that the influent TN and TP average 208 mg/l and 90 mg/l, respectively (Table 3.1), which
translates to >go% TN removal and >98% TP removal. For both periods, the average ammonia concentrations
achieved were less than 3.0 mg/l, indicating significant nitrification was occurring. The nitrate/nitrite concentration
increased from 5.8 mg/l to io mg/l following the anaerobic system installation. This indicates reduced denitrification
efficiency.
Although the current treatment processes provide partial nutrient removal, enhanced nitrogen removal was not
targeted, as Novozymes' effluent permit limitations did not require this level of treatment. The historical IUP TN and
TP limits are summarized in the table below.
As shown below, from IUP inception through August 2o16, Novozymes was not subject to TN limits, and the
concentration limits for ammonia ranged from 48 mg/l to 5 mg/l. TP limits for that same period ranged from 18 mg/l
to 5 mg/l to a mass based limit. For land application, per Novozymes' Non -Discharge Permit, treated wastewater is
land applied at agronomic loading rates but the permit does not contain numerical limits for TN or TP (Appendix A).
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 111

Table 3.3. Historical IUP Limits
15 mg/I monthly
40 mg/I monthly
September
Initial IUP
average, 18 mg/I daily
average, 48 mg/I daily
None
2008
Issuance
maximum
maximum
10 mg/I monthly
40 mg/I monthly
November
IUP
average, 12 mg/I daily
average, 48 mg/I daily None
2011
Modification
maximum
maximum
40 mg/I monthly
November
IUP
5 mg/I monthly average,
2012
average, 48 mg/I daily None
Modification
6 mg/I daily maximum
maximum
Winter: 29.4 mg/I
weekly average, 10.0
December
mg/I monthly average
IUP
5 mg/I monthly average,
2014
Modification
6 mg/I daily maximum
Summer. 15.0 mg/I
None
weekly average, 5.0
mg/I monthly average
Winter: 29.4 mg/I
weekly average, 10.0
295 Ibs/month monthly
1,516 Ibs/d monthly
August 2016
IUP
mg/I monthly average
average, 67.8 Ibs/week
average, 349 Ibs/d
Modification
Summer: 15.0 mg/I
average
weekly average
weekly average, 5.0
m /I monthly average
Uniform Limits.
November
295 Ibs/month monthly
1,825 Ibs/d monthly
IUP
29.4 mg/I weekly
2018
average, 67.8 Ibs/week
average, 420 Ibs/d
Modification
average, 10 mg/I
average
monthly average
weekly average
�•� Dewberry° Novozymes North America, Inc. I Best Available Technology Analysis 112
II!

4. TN TREATMENT TECHNOLOGY ALTERNATIVES EVALUATED
4.1 TN Treatment Technologies
Three (3) treatment technologies were evaluated to identify the BAT Economically Achievable limits for TN, which in
general represent the best existing performance of treatment technologies that are economically achievable within an
industrial point source category (EPA NPDES Permit Writers' Manual, 201o, EPA-833-K-io-ooi). The three (3)
treatment processes evaluated were simultaneous nitrification and denitrification (SND) processes in the following
continuous activated sludge configurations: extended aeration, conventional aeration, and high -rate aeration. SND
continuous flow activated treatment facilities operate at lower DO concentrations (0.50f0.2 mg/l on average), and
are able to achieve nitrification and denitrification in the same bioreactor tank. Recent studies have presented data
demonstrating over go% COD removal, and at increased carbon to nitrogen (C/N) ratios, nitrogen removal
efficiencies higher than 98% SND'.
The three technologies evaluated as part of the BAT analysis are best defined and differentiated by their food -to -
microorganism (F:M) ratios. The F:M ratio is a significant design and operational parameter of activated sludge
systems. The three technologies evaluated include extended aeration, conventional aeration, and high -rate aeration.
These three technologies typically are designed with the following F:M ratios:
• Extended Aeration, 0.05 < F:M < 0.15, (units of mg COD/mg MLVSS*day)
• Conventional Aeration, 0.25 < F:M < o.6o
• High Rate Aeration, 0.50 < F:M < 1.5
Novozymes has successfully operated high rate aeration, SND continuous flow WWTPs at its Kalunborg, Denmark
and Tianjin Shi, China facilities. The WWTPs at Kalunborg and Tianjin Shi achieve SND using automated DO control
based on feedback from nitrate and ammonia sensors installed within biological reactor trains.
The facility in China has successfully operated for the last 20 years. The WWTP there includes reactors which are
continuous flow that cycle and control aeration based on ammonia and nitrate concentrations to achieve SND while
operating at low dissolved oxygen concentrations. If ammonia concentrations increase above the specific set point,
aeration is turned up to increase DO to enhance nitrification. If nitrate concentrations increase above the specific set
point, aeration is turned down or off to create more favorable anoxic conditions to support denitrification. Multiple
reactors are utilized in parallel, and the reactor effluent discharges to secondary clarifiers.
Overall, the SND activated sludge process is an innovative process that reduces energy use by operating at decreased
DO concentrations and eliminates costly recirculation pumps and carbon addition compared to conventional
sequenced nitrification and denitrification activated sludge process. Three different technologies were evaluated for
operation using the SND process: (i) extended aeration, (ii) conventional aeration, and (iii) high rate aeration. The
evaluation included treatability testing, biological process modeling, and a comparison of equivalent annual costs.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 113

5. Treatability Testing
To establish and support proposed TN limits for the proposed Novozymes NPDES permit based on an analysis of the
Best Available Technology Economically Achievable, treatability testing was performed on three (3) treatment
technologies capable of achieving biological nitrogen removal. TP limits were established independently of
treatability testing, as described in Section 9.2. Although the existing treatment process provides partial nutrient
removal, enhanced nitrogen removal was not targeted, as Novozymes' effluent permit limitations did not require this
level of treatment, thus treatability testing was necessary to establish the TN limits attainable.
5.1 Treatability Testing Approach
Treatability testing was performed to establish the soluble refractory organic nitrogen and nitrate effluent
concentrations for each of the three technologies evaluated. The ultimate goal of treatability testing is to determine
the effluent refractory organic nitrogen and nitrate to support effluent limits for TN for the Novozymes NPDES
permit based on analysis of Best Available Technology Economically Achievable.
While ammonia and particulate organic nitrogen concentrations were tracked during the treatability study, it is
anticipated that these sub -components of total nitrogen will be based on water quality and limits of technology. It is
expected that the NPDES permit will contain a water quality based ammonia limit of 1.o mg/l. For particulate
organic nitrogen, it is assumed Novozymes will install tertiary filtration to remove particulate organic nitrogen. As
such, a technology based limit is proposed for this component of total nitrogen. Tertiary filtration is expected to
produce an effluent TSS of <3.0 mg/Lii. Assuming the TSS is biological in nature, e.g. biomass at 12% nitrogen, the
estimated particulate organic nitrogen expected from the filter effluent is 0.36 mg/l. For the purposes of the BAT
analysis, it is therefore assumed that the effluent ammonia limit will be 1.o mg/l and the effluent particulate nitrogen
concentration with tertiary filtration is estimated to be 0.36 mg/L.
The treatability testing protocol was developed to best simulate this full-scale treatment technology. Since automated
DO control is difficult to implement within bench scale testing, a sequencing approach was utilized to simulate the
reactors and demonstrate treatability. The bench scale reactors were operated as true batch reactors, without
continuous feed/draw, due to the challenges associated with balancing flow rates to maintain continuous flow
conditions on a small scale.
Initially, to mimic continuous flow in a batch reactor vessel, the testing involved several cycles of aeration/anoxic
conditions. Early testing results revealed ineffective denitrification with this approach, as nitrate concentrations were
high at end of batch. This is likely due to the lack of COD for substrate in the later anoxic cycles. In response, the
protocol was revised to operate with only one aerobic and anoxic cycle per batch. This change in protocol would
mimic the control logic of the Novozymes reactors and confirm that robust SND could be achieved with the
Novozymes Franklinton, NC wastewater.
Under the revised protocol, bench scale reactors were operated with a distinct aeration phase which was terminated
upon achieving an ammonia -nitrogen concentration less than 1.o mg/L to simulate the full-scale control logic when
aeration is activated. The bench scale reactors were then operated with an anoxic phase with supplemental carbon
addition until the nitrate reached a concentration less than 1.o mg/L to simulate the full-scale control logic when the
aeration is deactivated and the reactors are in mix phase. This sequence represented one reaction batch in the bench
scale reactors. Full-scale, this sequence would repeat continuously in small time increments in the continuous flow
through reactors.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 114

5.2 Treatability Testing Protocol
The treatability testing protocol was approved by the Division in 2017. Treatability testing was performed in 2-liter
reactors mixed on a Phipps & Bird jar tester. Reactors were aerated with diffuser stones and miniature air pumps.
Each reactor was operated at different F:M loading rates to mimic the three evaluated technologies:
Reactor i = Extended Aeration at F:M of o.i (units of mg COD/mg MLVSS*day),
• Reactor 2 = Conventional Aeration at F:M of 0.5, and
• Reactor 3 = High Rate Aeration at F:M of 0.7.
Initially, from July 12-July 20, 2017, reactors were operated with multi -phased nitrification/denitrification by cycling
the aerators on/off in 3o-minute intervals. This protocol was intended to simulate continuous flow SND. After
running multiple batches under this configuration, effluent data indicated nitrate concentrations were higher than
expected and that sufficient carbon was not remaining during the later anoxic cycles to support complete
denitrification. These results were not entirely unexpected, as the reactors were not operated with continuous
influent feed and therefore the rate of denitrification was very low. This differs from the approach that will be
implemented full-scale, which includes continuous feed to provide carbon to support higher denitrification rates. In
addition, the aeration/anoxic phases on the bench scale were operated on a timed basis rather than utilizing real time
data (NH3 and NO3) to control DO as will be the operational approach full-scale.
For testing performed from July 21 — August 4, 2017, the protocol was modified for each batch to operate with a
single aerobic cycle followed by a single anoxic cycle. Supplemental carbon was added to the reactors at the beginning
of the anoxic cycle to support higher denitrification rates. The final protocol included the following sequence:
1) Feed
a) Feed Novozymes wastewater at volumes required to achieve the three food -to -mass loading conditions
2) Aeration Cycle
a) Aerate the reactor until the reactor ammonia concentration is < 1.o mg/L
3) Anoxic Cycle
a) Stop aeration and continue mixing the reactor
b) Dose supplemental carbon (acetic acid) to support denitrification at a Chemical Oxygen Demand (COD)
to Nitrate ratio of 6
c) Mix the reactor until the reactor nitrate is < 1.o mg/L
4) Settle
a) Stop mixing and allow biomass to settle
5) Decant
a) Decant reactor and collect effluent samples for analysis
Effluent samples were analyzed both by a certified laboratory and by Dewberry personnel. Dewberry analyzed
samples using Hach test kits to identify the end of aeration/anoxic cycles and to assess reactor performance in real
time. The results presented within this report used to establish effluent limits are based solely on certified laboratory
data. Due to large sample volumes required by the certified laboratory, effluent from approximately two to three
reactor batches were composited to create a certified laboratory sample.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 115

The reactors were analyzed weekly for total suspended solids and volatile suspended solids. Reactors were also
monitored regularly for pH and dissolved oxygen. Reactor pH was adjusted as needed to maintain the pH at
approximately 7.5-9 standard units (s.u.). Reactor batch effluent samples were analyzed by the certified laboratory for
the following parameters:
• Soluble COD . NH3
• Soluble Carbonaceous 5-day BOD Soluble TKN
NOVNOZ . Soluble sTKN
Table 5.2 presents the nitrogen species evaluated during the treatability testing and the source of the results
(measured versus calculated). Effluent soluble total nitrogen (sTN) and soluble organic nitrogen (sOrgN) were
calculated using Equation 1 and Equation 2, respectively.
Equation 1: sTN(calculated) = STKN(measured) + NO3(measured) + NO2(measured)
Equation 2: s0r^calculated) = STKN(measured) — NH3(measured)
Table 5.1. Treatability Testing Nitrogen Speciation Parameters
sTKN Soluble Total Keldahl Nitrogen Measured
NO3
Nitrate
Measured
NO2
Nitrite
Measured
NH3
Ammonia
Measured
sTN
Soluble Total Nitrogen
Calculated
sOr N
Soluble Organic Nitrogen
Calculated
5.3 Performance Testing Results
Performance testing was performed over a 19-day period beginning July 21, 2017 and ending August 9, 2017. During
this time, six (6) wastewater influent samples were collected from Novozymes to utilize in feeding the reactors.
Using the collected Novozymes wastewater batch samples, seventeen (17) treatability testing batches were performed,
M1 through M17, using the protocol previously described. Effluent reactor results were analyzed by a certified
laboratory, and the results are presented in Appendix I. Reactor logs and process control laboratory analyses
performed by Dewberry are presented in Appendix J. Results in Appendix J were used to aid in reactor operations
(e.g. when to terminate cycles, adjust pH, etc.) and were not used to calculate BAT TN limit. Only certified laboratory
results were used to calculate the BAT TN limit.
A comparison of certified lab data to internal process control lab data identifies a positive correlation for the 17
treatability test batches performed, with the exception of Reactor 3: High Rate Aeration (0.7 F:M), which exhibited a
poor correlation for batches M6 — Mil. Table 5.2 below provides the calculated variability between average internal
process and certified lab data.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 116

Table 5.2. Calculated Variability between
Measured Internal Process and Certified Lab Data
(,)Data presented in Table 3 is represents the absolute difference between the average value
of internal process measurements and average value of certified laboratory analysis.
(z)Omits data from Batch Run M6 - Mil.
Internal process data collected for Reactor 3 during the six treatability batch runs, batches M6-Mil, indicates average
NH3 and sTKN concentrations of 0.47 and io.8 mg/l respectively. Certified laboratory results indicate average NH3
and sTKN concentrations of 16.5 and 28.6 mg/l respectively. This is a variability of over 15 mg/l between internal and
certified laboratory data for both parameters. In comparison, the variability of batch tests Mi — M17 for the three (3)
reactor configurations, omitting data from Reactor 3 batches M6-Mil, results in an average NH3 and sTKN variability
of less than 0.32 and 3.73 mg/l, respectively. Due to the high variability between internal process and certified lab
data for Reactor 3 batch tests M6-Mil, the certified lab data for these batches are to be omitted in the final
calculations to determine the BAT limits for nitrogen. It should be noted that inclusion of the Reactor 3 batches M6-
Mii would result in a higher BAT limit for that technology. The decision to omit these results from the BAT limit
calculation was approved by the Division in September 2018 (Appendix Q.
Table 5.3 summarizes the 95th percentile and maximum reactor effluent certified lab data results. The 95th percentile
reactor effluent is presented, as that data is used to develop the effluent total nitrogen limit. This is consistent with the
EPA's methodology for establishing monthly average effluent limits. The 95th percentile is the basis for long-term
average in order to accommodate reasonably anticipated variability within the control of the facility (EPA NPDES
Permit Writers' Manual, 201o, EPA-833-K-io-ooi).
Table 5.3. Treatability Testing 95th Percentile and Maximum Reactor Effluent Results (')
Reactor 1 Reactor 2 Reactor 3
F:M 0.1 F:M 0.5 F:M 0.7 (3)
Parameter Units 95th (2) MAX 95th MAX 95th MAX
WData presented in Table 3 is based on certified laboratory data.
(2)Value represents 95th Percentile
(z)Omits data from Batch Runs M6 - Mil.
With the exception of nitrate, the effluent nitrogen species increased in concentration with increasing food -to -mass,
as expected. The 95th percentile effluent refractory soluble organic nitrogen ranged from 1.28 — 11.6 mg/l, increasing
with increasing food -to -mass, and comprised 4o%-96% of the total nitrogen. If data from batches M6-Mil was
included in the Reactor 3 analysis, the maximum effluent concentration for soluble organic nitrogen would increase
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 117

from 12.7 to 13.2 mg/l. Using the 95tn percentile data yields a more stringent, yet achievable, BAT TN limit..
Maximum concentrations were at most io% greater than 95th percentile results and as such further modeling and
BAT calculations for each alternative technology were performed only using the 95th percentile data. The effluent
refractory soluble organic nitrogen and nitrate were then used to develop an effluent total nitrogen limit for each
technology evaluated (see Section io below).
Dewberry, Novozymes North America, Inc. I Best Available Technology Analysis 118

6. PROPOSED PROCESS TREATMENT DESCRIPTION
Following treatability testing, Dewberry performed preliminary design calculations for each technology to evaluate
WWTP upgrades necessary to achieve TN removal at Novozymes' projected direct discharge flow of 2.0 MGD. In
addition to processes largely responsible for TN removal, other unit processes were evaluated as necessary to comply
with expected limits for BOD5, TP, and TSS and to accommodate the higher future flow rates. For the purpose of this
BAT analysis, it is assumed that the existing anaerobic up -flow reactor will continue to be used for side stream pre-
treatment of COD of the permeate stream. Per the anaerobic system design specifications, it is assumed that use of
this system will provide COD reduction of 24,00o lb/day. Treated effluent from the anaerobic reactor will mix with
the remaining influent wastewater prior to the proposed SND treatment process. The raw influent wastewater
characteristics, as well as the influent to the proposed SND process, are presented in the table below.
Table 6.1. Novozymes' Influent Wastewater Average Conditions to SND Activated Sludge Process
COD
m /I
5,389
3,950
COD
lbs/day
89,900
65,900
TKN
m /I
197
197
NH3
m /I
63
63
NO3/NO2
m /I
29
29
TP
m /I
90
90
*After anaerobic pretreatment of 24,000 lbs/d COD.
A block flow diagram detailing Novozymes' proposed wastewater treatment upgrades is attached as Appendix K. The
following section provides sizing criteria for major equipment required to upgrade the existing facility to a SND
activated sludge process. This section also identifies which unit processes were included in the economic analysis to
identify proposed BAT TN limits. Major equipment to be installed is summarized in the attached preliminary
equipment specification table in Appendix L. Detailed discussion related to biological process modeling is provided
below in Section 7.
6.1 Primary Clarification
A new primary clarifier is required to supplement the existing primary clarifier due to the increased hydraulic and
solids loading to the treatment process. The primary clarifier shall reduce solids present in the influent wastewater.
The primary clarification unit process step shall also include capacity for phosphorus removal through chemical
precipitation, such as the addition of ferric chloride.
Using October 201.6- October 2018 flow data, the historical average flow to the primary clarifiers was 0.76 MGD,
resulting in an overflow rate of 790 gal/ft2/d for the existing clarifier. This historical overflow rate of 790 gal/ft2/d is
nearly within the recommended loading rate of 800-1,200 gal/d/ft2 for primary clarifiers (Metcalf & Eddy, pg. S98).
This loading rate has provided sufficient settling of solids for the Novozymes facility in the past, and the same
overflow rate was used to size the new primary clarifier.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 119

The proposed upgrade for this unit process will be consistent between all three treatment technologies evaluated,
and therefore is not included in the BAT economic analysis to determine BAT TN limits
6.2 Bioreactors
Above ground, bolted stainless steel bioreactor tanks shall be provided for the proposed SND activated sludge system.
Bioreactor tanks were sized for each evaluated technology to provide the required process volume based on the
selected F:M ratio, mixed liquor volatile suspended solids (MLVSS) concentration and influent COD loading. For the
purpose of the BAT analysis, it is assumed that each technology shall operate a MLVSS concentration of 4,000 mg/l
with an influent COD concentration identified in Table 6.1. Setting the MLVSS and COD concentrations constant
allows the bioreactor volumes to be calculated from the selected F:M ratio.
Therefore the bioreactor volume for each technology evaluated will differ as identified in the attached preliminary
equipment specification table (Appendix L). The required bioreactor configuration for the conventional aeration
treatment technology, e.g. F:M = 0.5, was provided to vendors for pricing. Bioreactor costs for the extended aeration
and high rate aeration technologies were scaled accordingly from received vendor quotes. Such costs shall be
included in the BAT economic analysis to determine BAT TN limits.
6.3 Aeration Equipment
Bioreactor tanks will be equipped with fine bubble diffuser aeration grids and surface mixers. Air supply will be
provided by positive displacement or centrifugal blowers for the required design air flow and pressure as identified in
the attached preliminary equipment specification table (Appendix Q. Each bioreactor tank shall have dedicated
aeration grids and blowers. Mixing shall be provided by fixed or floating direct drive mixers. As the different
technologies operate at varying F:M ratios, the required oxygen supply will also vary due to variable solids retention
time (SRT) and biosolids generation rates.
The required aeration equipment for each technology will differ as identified in the attached preliminary
specification table (Appendix L). The required design air flow rate and pressure, tank size and TSS concentrations for
the conventional aeration treatment technology, e.g. F:M = 0.5, was provided to vendors for pricing on diffused
aeration grids, centrifugal blowers, and tank mixers. Additional pricing was also identified for the positive
displacement aeration blowers for the extended aeration process, e.g. F:M = o.i. Blower and tank costs for the
extended and high rate aeration technologies were scaled accordingly from received vendor quotes. Such costs shall
be included in the BAT economic analysis to determine BAT TN limits.
6.4 Secondary Clarification
A new concrete secondary clarifier is required to supplement the existing secondary clarifier to treat the higher future
flow rate conditions. The return activated sludge (RAS) and waste activated sludge (WAS) pump station will also
require modifications and upgrades. The new RAS pumps will provide 150% of influent flow return, while the WAS
pumps will be sized to maintain the desired MLVSS concentration. Both pumps will be self -priming pumps.
The proposed secondary clarifier is sized based on the historical solids loading rate. Historically, the existing
secondary clarifier operated at a solids loading rate of 0.51 pounds per day per square foot (gal/hr/ft2). The historical
solids loading rate was calculated based on an existing clarifier diameter of 87 ft and an average historical clarifier
influent flow rate of 0.73 MGD. The historical solids loading rate is below the recommended loading rate of 1.0-1.5
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 120

lb/hr/ft2 for secondary clarifiers (Metcalf & Eddy, pg. 687). Using the projected flow of 2.0 MGD, the secondary
clarifier was sized to maintain the historical solids loading rate for all three technologies.
The proposed upgrade for this unit process will be consistent between all three treatment technologies evaluated,
and therefore is not included in the BAT economic analysis to determine BAT TN limits.
6.5 Dissolved Air Flotation (DAF)
Chemical precipitation is currently employed onsite for phosphorus removal and additional treatment capacity is
required for the flow increase. Novozymes currently utilizes a ioo ft2 DAF with ferric chloride and lime addition for
phosphorus removal. Historically, the DAF has been operated at an average surface loading rate of 2.9 gpm/ft2. This
surface loading rate is calculated based on the 2014-2015 average effluent flow rate to Franklin County of 0.423 MGD.
The historical surface loading rate is within the recommended range of 0.2 — 4.0 gpm/ft2 for dissolved air flotation
(Metcalf & Eddy, pg. 423).
Two additional DAFs at 250 ft2 each are proposed to supplement the existing DAF. The surface loading rate for the
new DAFs and the existing DAF at 2.0 MGD will be 2.3 gpm/ft2, which is below the historical surface loading rate and
within the recommended range. In addition, Novozymes will have the ability to vary the ferric addition rate as needed
to achieve phosphorus removal.
Since the sizing criteria for the DAFs is flow -based, the proposed upgrades to the DAF system and the upgrade costs
will be the same for each treatment technology. Also DAF costs are for TP removal and not TN removal, thus such
costs shall not be included in the BAT economic analysis to determine BAT TN limits.
6.6 Reverse Osmosis (RO) System
The reverse osmosis system is included to reduce the concentration of total dissolved solids (TDS), principally
potassium, in the Novozymes' discharge. It is also anticipated that the RO system will provide, on average,1.o mg/1
total nitrogen removal.
RO reject will be sent to an evaporator, with bottoms disposed of at an approved facility. Novozymes is currently
seeking environmentally advantageous disposal options for evaporator bottoms, but has yet to finalize reuse options
at this time.
Since the sizing criteria for the RO system is based on TDS removal, principally potassium removal, costs
associated the RO system and associated evaporators are not included in the BAT economic analysis to determine
BAT TN limits.
ItDewberry Novozymes North America, Inc. I Best Available Technology Analysis 121

7. BIOLOGICAL PROCESS MODELING
Dewberry performed biological process modeling using Biowin® for each proposed technology. The purpose of
biological process modeling was to evaluate the ammonia, nitrate/nitrite and organic nitrogen concentrations present
in the effluent wastewater stream; effluent TP concentrations were not evaluated through process modeling. The
influent conditions used in each model are presented in Table 5.2, with the 95th percentile soluble refractory organic
nitrogen influent concentrations determined from treatability testing as presented in Table 5.4. A biological process
model was constructed for each technology assuming a SND process. Appendix M is a summary of input and output
parameters from Biowin.
Each model consists of a bioreactor with a DO concentration ranging from 0.3 to 0.5 mg/L. Using a mixed liquor
suspended solids (MLSS) concentration of 4,000-4,500 mg/l, the bioreactor for each technology was sized to achieve
the appropriate F:M ratios. The existing above ground and in -ground 0.24 MG tanks (Toi and Toe) were
incorporated into the model for polishing SND treatment of ammonia and nitrate downstream of the bioreactors. The
biological system was modeled as completely mixed, aerated reactors modeled in series, using a DO concentration
ranging from 0.2 to 0.5 mg/L. The total required surface area of the two secondary clarifiers are included as one
clarifier in the model. Figure 3 provides a schematic of the model unit processes.
Alkalinity
NZNA Wastewater
a�-
Bioreactor
Sludge
Figure 3. Biowin° Model Diagram
Effluent
To simulate the SND process, Dewberry utilized a low dissolved oxygen concentration approach, along with Biowin's
typical biological process kinetics, with exception of select kinetics rates and constants modified from default values
as indicated in Table 7.1 below. Modified values were determined from a literature review ii.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 122

Table 7.1. Biowin° Kinetic Values
Heterotro hic DO half saturation constant
m -Oz/L
0.0500
0.300
Ammonia oxidizing bacteria DO half saturation constant
m -Oz/L
0.2500
0.1500
Anoxic NO2 half saturation constant
m -N/L
0.0100
0.0500
Ammonia nutrient half saturation constant
m -N/L
0.0050
0.0001
The results of the process modeling indicate that ammonia and nitrate/nitrite concentrations are reduced to less than
1.o mg/L for each technology. Table 7.2 below lists the predicted effluent concentrations of ammonia, nitrate/nitrite,
and recalcitrant organic nitrogen for each technology evaluated. Therefore, it is anticipated that the proposed
treatment technologies evaluated can meet the speculative water quality limit for ammonia of 1.o mg/l.
Table 7.2. Biowin Effluent Nitrogen Results
Parameter `
Min @I
Extended Conventional
Aeration Aeration
F/M = 0.1 F/M = 0.5
High -Rate
Aeration
F/M = 0.7
Total Nitrogen
The results of process modeling represent effluent from secondary treatment and are not representative of final
tertiary treated wastewater. Process modeling predicts a secondary effluent TSS concentration of approximately 17
mg/l for each technology evaluated. Tertiary filtration is expected to produce an effluent TSS of <3.0 mg/L.
Assuming the TSS is biological in nature, e.g. biomass at 12% nitrogen, it is estimated that the tertiary filter will
reduce the secondary effluent TN concentration by 1.7 mg/l for each technology, calculated as follows: (17.0 mg/1-
3.0 mg/1)*.12% =1.7 mg/l. Table 7.3 provides the estimated tertiary effluent TN concentrations as well as the
modeled secondary treated effluent TN concentrations. These values correspond well with the proposed BAT TN
concentrations determined from treatability testing as presented in Section 9.o.
Table 7.3 Modeled and Estimated Effluent Nitrogen Conditions
=FAAeration
Parameter
Secondary Treatment Effluent TN
.High
Aeration
F/M =
4.49
10.1
-Rate
Aeration
14.4
Secondary Treatment Effluent TSS
16.5
17.4
17.2
Tertiary Filter Effluent TSS
3.0
3.0
3.0
Tertiary Filter TN Reduction
1.6
1.7
1.7
Tertiary Filter Effluent TN
< 3.0
8.4
12.7
91 Dewberry® Novozymes North America, Inc. I Best Available Technology Analysis 123

8. EQUIVALENT ANNUAL COST ANALYSIS
Utilizing the results of the preliminary design and process modeling, capital and operating opinions of probable cost
were developed for each technology evaluated to establish the equivalent annual costs for TN removal. Costs for TP
removal were not evaluated. Opinions of probable cost were developed for the following technologies:
• Alternative 1- Extended Aeration
• Alternative 2 — Conventional Aeration
• Alternative 3 — High Rate Aeration
Capital costs were included for treatment equipment and appurtenances which are related to TN removal, and
included estimates for installation costs, with allocations for contractor overhead, profit, and general conditions,
engineering, and construction labor and construction management. Annual recurring operational costs were
estimated for chemicals, residuals disposal, utilities, sewer use fees, maintenance and nutrient offset fees.
Capital costs were estimated for Alternative 2 based on vendor quotes and installation factors. For Alternatives i and
3, the capital and annual recurring costs for Alternative 2 were scaled when appropriate. For example, the capital
costs for the bioreactors were scaled as the required reactor volume will increase with a decreasing food -to -mass. A
discussion of which costs were included was presented previously in Section 6.o for each proposed unit process. For
this reason, some of the items presented in the cost estimates included in the concurrently submitted EAA report are
not included in the BAT cost estimates. The BAT cost estimates only focus on capital equipment costs necessary for
biological TN removal, thus making the BAT cost estimates a subset of the EAA cost estimates.
Capital and recurring opinions of probable cost for each alternative are presented in Appendix N. The opinions of
probable cost were converted to an equivalent annual cost based on a 5-year period and an annual discount rate of
7%, which are the standard assumptions used by Novozymes to evaluate project financials. Table 8.1 summarizes the
capital, operating, and equivalent annual costs for each alternative.
ItDewberry Novozymes North America, Inc. I Best Available Technology Analysis 124

Table 8.1. Equivalent Annual Costs Comparison
Capital Costs
Equipment Installation and Construction
40% Contingency
Engineering and Construction Management
Extended.
Aeration
$25,507,000
Aeration
$7,969,000
Aeration
$6,199,000
$10,200,000
$3,188,000
$2,480,000
$3,570,000
$1,116,000
$868,000
Total Required Capital Costs
Reoccurring Costs
O&M, including chemicals, labor and maintenance
$39,277,000
$473,000
$12,273,000
$313,000
$9,547,000
$303,000
Laboratory Costs
$42,000
$42,000
$42,000
Residuals Disposal Costs
$3,035,000
$3,550,000
$3,893,000
Sewer Use Fees
$365,000
$365,000
$365,000
Tar -Pamlico Nutrient Off Set Fees
$173,000
$173,000
$173,000
Utility Costs
$4,019,000
$892,000
$746,000
Total Annual Recurring Costs
$8,107,000
$5,335,000
$5,522,000
Dewberry, Novozymes North America, Inc. I Best Available Technology Analysis 125

9. BAT LIMIT DETERMINATION
9.1 Total Nitrogen BAT Limits
Novozymes commissioned the treatability testing to support development of BAT TN limits for the proposed NPDES
discharge. To determine BAT TN limits for the discharge, the treatability testing results and cost estimates were used
to compare the economic factors for the alternatives evaluated. This process is summarized below:
i. Identify achievable effluent total nitrogen limits for each technology evaluated.
2. Develop Equivalent Annual Costs for each technology evaluated.
3. Calculate normalized nitrogen removal costs for each design technology evaluated based on the equivalent
annual cost and total annual mass of nitrogen removed.
4. Compare the normalized nitrogen removal costs for each technology evaluated to each other.
The effluent total nitrogen limits presented in Table 9.1 were developed based on the sum of the following sub-
components: soluble organic nitrogen, nitrate/nitrite, ammonia, and particulate total nitrogen. The effluent soluble
organic nitrogen and nitrate components presented are based on the 95th percentile treatability testing results for
each technology evaluated. The 95th percentile reactor effluent concentrations were used to develop the effluent total
nitrogen limit to be consistent with the EPA's methodology for establishing monthly average effluent limits. The
ammonia effluent limit is assumed to be water quality based at i.o mg/l. The particulate total nitrogen is estimated to
be 0.36 mg/l for tertiary filter effluent based on assuming a biological TSS filter effluent of 3.0 mg/l.
Table 9.1 presents the calculated effluent total nitrogen BAT limits proposed for each technology evaluated.
Calculated effluent total nitrogen BAT limits are also presented graphically in Figure 4.
Table 9.1. Calculated Effluent Total Nitrogen BAT Limits
.
Parameter Units Basis
• . N mg/l..
Alt.1
Extended
Aeration
0.1 F:M
Alt.2
Conventional
Aeration
0.5 F:M
Alt.3
High Rate
Aeration
0.7 F:M
1111111101[917101•��M
Treatability
Water Quality
Particulate TN
Performance
.Assumed
Effluent BAT TN Limit mg1l
Value
N Calculated as
sum of above
3.8
8.8
12.7
Achievable effluent ammonia concentrations have been confirmed through biological process modeling
2 The particulate TN is estimated assuming filter effluent solids are 12% nitrogen and based on tertiary filter performance
estimates from Metcalf & Eddy Inc. (2003) Wastewater Engineering Treatment and Reuse (4th Ed). New York, NY: McGraw-
Hill.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 126

14
12
or
10
E g
J
Z
a 6
a0
Po Legend:
2 - t
0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8
Operating F:M
of
Aft.
Alt. 3e
r
r
Figure 4. TN Effluent Results Comparison
For reference, the use of maximum treatability testing results in lieu of 95th percentile results would increase the
proposed effluent BAT TN limits to 3.9, io.6 and 13.9 mg/l for Alternatives 1, 2, and 3 respectively. This accounts for
the 1.o mg/l RO credit. Using the 95th percentile results in lieu of the maximum results represents percent decreases
Of 3%,17%, and 9%, respectively of three technologies evaluated.
For each technology evaluated, the annual mass of nitrogen removed was calculated based on the design flow rate, the
influent TN, and the effluent BAT total nitrogen limits provided in Table 9.1. A normalized nitrogen removal cost was
then calculated based on the mass of nitrogen removed and the annual equivalent cost.
Table 9.2. Equivalent Annual Costs Normalized to Nitrogen Removed
Influent Total Nitrogen
mg/I
226
3.8
226
226
Effluent Total Nitrogen Limit
mg/I
8.8
12.7
% Nitrogen Removal
%
98.3%
96.1 %
94.3%
Flow
MGD
2
2
2
Annual Mass of Nitrogen
Removed
Ib/yr
1,352,798
1,322,357
1,298,613
Equivalent Annual Cost
$
$17,700,000
$8,300,000
$7,900,000
Normalized Nitrogen
Removal Cost
$/Ib
13.08
6.28
6.08
As indicated in Table 9.2, the normalized nitrogen removal cost ranges from $6.o8 for Alternative 3 to $6.28 for
Alternative 2 to $13.o8 for Alternative i. The cost for Alternative i is more than double the costs for Alternatives 2
Novozymes North America, Inc. I Best Available Technology Analysis 127

and 3, while providing minimal increase in nitrogen removal efficiency (<4%). Figure 5 below illustrates the
normalized nitrogen removal costs for each alternative. The graphical relationship depicts a much steeper slope
between Alternatives i and 2 compared to Alternatives 2 and 3. This indicates that there is significant additional
incremental cost to achieve the limits proposed for Alternative 1 compared to Alternative 2 and 3.
$14.00
z
Alt.
1
Legend:
Figure 5. Normalized Nitrogen Removal Costs
Table 9.3 below provides a summary of the cost differential between the Alternatives and the increase in mass of
nitrogen removed.
Table 9.3. Incremental TN Removal Cost Comparison
vs. vs vs
Additional Annual Nitrogen Removed Ib/yr 30,441 54,185 23,744
Additional Equivalent Annual Cost $ $9,400,000 $9,800,000 $400,000
Incremental Normalized Cost Increase for
Additional Nitrogen removal $/Ib $309 $181 $16.9
A review of the costs and associated information indicates that Alternative 2 is the best available alternative that is
economically achievable. The basis for this analysis is summarized below:
The Alternative 2 normalized nitrogen costs are 52% less and 3% more compared to Alternatives 1 and 3,
respectively. The graphical relationship between the costs indicate significant incremental cost increase
between Alternatives 2 and 1. Relationship between Alternatives 2 and 3 reveals a much lower incremental
cost increase.
Novozymes North America, Inc. I Best Available Technology Analysis 128

The additional annual costs to remove 23,774 lbs of nitrogen, the difference between Alternatives 2 and 3, is
approximately $16.9 per additional lb TN removed. This is deemed to be economically feasible and
reasonable.
The additional annual costs to remove 30,441 lbs of nitrogen, the difference between Alternatives 1 and 2, is
approximately $309 per additional lb TN removed. This is deemed to be economically infeasible and
unreasonable.
Estimated utility costs for Alternative 2 is 78% less than Alternative 3. Utility costs for Alternatives 2 and 3
are similar.
The total annual reoccurring costs for Alternative 2 is 34% less and 3.0% less compared to Alternatives 1 and
3, respectively.
Factors considered in assessing BAT include the cost of achieving BAT effluent concentrations, the age of equipment
and facilities involved, the processes employed, engineering aspects of the control technology, potential process
changes, non -water quality environmental impacts (including energy requirements), and economic achievability.
Based on the equivalent annual costs and normalized nitrogen removal costs, Alternative 2, Conventional Aeration,
F:M = 0.5, proves to be the best performing alternative evaluated that is economically reasonable, and thus is deemed
the basis for the Best Available Technology Economically Achievable (BAT) limit for TN. Therefore, the proposed
monthly average total nitrogen limit is provided in Table 9.4. This value assumes a 1.o mg/l reduction from the
reverse osmosis system.
Table 9.4. Proposed Total Nitrogen BAT Limit
Monthly Average
Proposed Limit
Total Nitrogen I 8.8 mg/I
For reference, municipal TN surcharge rates within the State of North Carolina were compiled and are presented in
Table 9.5. Nitrogen removal unit costs for industrial wastewater treatment plants are not publicly available, so
municipal TN surcharge rates were used for this comparison. Municipal nitrogen surcharge rates represent the costs
municipalities impose on industrial dischargers to treat nitrogen in excess of typical municipal concentrations within
their POTWs and provide an indication of reasonable and economically achievable treatment costs. The average total
nitrogen surcharge rate based on 5 municipalities in North Carolina is $1.96/lb of nitrogen. The maximum surcharge
rate based on the 5 municipalities is $5.00/lb of nitrogen. The normalized nitrogen removal costs for the three
technologies evaluated for the Novozymes facility exceed the average and maximum municipal surcharge rates.
While the normalized nitrogen removal costs for Alternatives 2 and 3 are 22-26% higher than the maximum
municipal surcharge rate, Alternative 1 costs are more than 2.5 times the maximum municipal surcharge cost. This
analysis provides additional support for the selection of Alternative 2 as the basis for BAT total nitrogen limit.
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 129

Table 9.5. North Carolina Municipal Total Nitrogen Surcharge Rate Comparison
Town of Cary
I $1.30
Franklin County
I $5.00
City of Raleigh
$1.85
Town of Conover
$ 0.63
City of Greenville
$1.04
Maximum
$ 5.00
Average
$ 1.96
Alternative 2:
Conventional Aeration, 0.5 F:M 1 $6.28
9.2 Total Phosphorus BAT Limits
Review of recent TP data (Appendix G) indicates a sixteen month period where the monthly effluent TP averaged less
than i.o mg/l. This demonstrates that phosphorous removal to less than i.o mg/1 is technically feasible with chemical
precipitation. The data is not consistently below the proposed limit because Novozymes is not currently required to
meet a monthly average TP limit of 1.o mg/L and therefore does not dose chemical at the rate required to consistently
maintain that level of treatment. Theoretically, for chemical precipitation of phosphorous, the effluent ortho-
phosphate concentration is directly related to the chemical dose (Metcalf & Eddy, pg. 5o6). Figure 5 below presents
the effluent TP concentrations as a function of the metal coagulant dose'°. It should be noted that the data in Figure 5
is presented on a logarithmic scale; therefore to achieve additional effluent TP of o.i.o mg/L requires approximately
2-10 times the chemical dose to achieve TP of i.o mg/l.
In the future, Novozymes will increase the chemical dose to consistently achieve effluent TP < i.o mg/L. A BAT of i.o
mg/L is deemed appropriate as significantly higher chemical dose ratios are required to produce nominal decreases in
effluent TP in the range below i.o mg/L, as demonstrated in Figure 5. In addition, the proposed WWTP upgrades will
include chemical addition in the primary clarifiers to support chemical phosphorus precipitation and tertiary
filtration to provide particulate TP removal. Therefore, Novozymes proposes an effluent BAT limit of i.o mg/L TP.
Table 9.6. Proposed Phosphorus BAT Limit
Total Phosphorus 1.0 mg/I
tjDewberry Novozymes North America, Inc. I Best Available Technology Analysis 130

10.000
1.000
00
10
1
0.001
I
1 1
I I
1 1
I I
� ♦ � 1 1
i I I
1 ii 1
( � I
I
1 ,yyy.
• 1
Effluent P (mgll)
0.100
1 000
Figure 6. Effluent Phosphorus Concentration vs Metal Coagulant to Phosphorus Dose
•�' Novoz mes North America, Inc. Best Available Technology Analysis 31
�� Dewberry Y 9Y Y

10.CONCLUSIONS
The proposed discharge location on Cedar Creek is located in the Tar -Pamlico River Basin. As a result and as
discussed in correspondence from the Division dated December 14, 2016 (Appendix D), the Division requested that
Novozymes prepare and submit a Best Available Technology Economically Achievable (BAT) analysis to assist in
establishing limits for TP and TN. Three (3) treatment technologies were evaluated to identify the BAT Economically
Achievable limits for TN, which in general represent the best existing performance of treatment technologies that are
economically achievable within an industrial point source category (EPA NPDES Permit Writers' Manual, 20io, EPA-
833-K-io-ooi). The treatment technologies evaluated were:
• Alternative is Extended Aeration at F:M of o.l (units of mg COD/mg MLVSS*day)
• Alternative 2: Conventional Aeration at F:M of 0.5
• Alternative 3: High Rate Aeration at F:M of 0.7
Treatability testing was performed to determine the effluent soluble refractory organic nitrogen and nitrate for each
technology evaluated. The technically achievable effluent total nitrogen concentrations were calculated from the sum
of the 95th percentile effluent soluble refractory organic nitrogen for each reactor, the 95th percentile effluent nitrate
from each reactor, the ammonia monthly average limit of 1.o mg/L, and the estimated particulate total nitrogen of
0.36 mg/l. The technically achievable effluent total nitrogen concentration for the three design conditions were
determined to be 3.8 mg/l, 8.8 mg/l and 12.7 mg/l; this includes a nitrogen removal credit of 1.o mg/l from the RO
treatment process. Biological process modeling was also performed that identified that each alternative would
produce secondary effluent with NH3 and NO3 concentrations of less than i.o mg/L, each.
The EPA definition of a BAT limit requires it be both technically and economically achievable. Capital and annual
recurring costs were estimated for each of the three technologies evaluated and were used to determine annual
equivalent costs. For the BAT TN limit, the annual equivalent costs were normalized per pound of nitrogen removed
for each alternative evaluated and are summarized in Table io.i.
Table 10.1. Summary of Equivalent Annual Costs Normalized to Nitrogen Removed
Equivalent Annual Cost
$
$17,700,000
$8,300,000
$7,900,000
Normalized Nitrogen
Removal Cost
$/lb
13.08
6.28
6.08
Based on the equivalent annual costs and normalized nitrogen removal costs, Alternative 2, Conventional Aeration,
F:M = 0.5, proves to be the highest performing alternative evaluated that is economically achievable, and is deemed
the Best Available Technology Economically Achievable limit. Normalized nitrogen costs for Alternative 2 are 52
less and 3% more compared to Alternatives i and 3, respectively. The graphical relationship (Figure 4) between
Normalized nitrogen costs indicate significant incremental cost increase between Alternatives 2 and 1. The graphical
relationship between Alternatives 2 and 3 reveals a much lower incremental cost increase. The Equivalent Annual
Costs for Alternative 2 is 53% less and 5% more compared to Alternatives 1 and 3 respectively. The additional annual
costs to remove 23,774 lbs of nitrogen, the difference between Alternatives 2 and 3, is approximately $16.9 per lb TN
removed. This is deemed to be economically feasible and reasonable. The additional annual costs to remove 30,441
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 132

lbs of nitrogen, the difference between Alternatives 1 and 2, is approximately $309 per lb TN removed. This is
deemed to be economically infeasible and unreasonable.
For TP, a BAT of i.o mg/L is deemed appropriate as significantly higher chemical dose ratios are required to produce
nominal decreases in effluent TP in the range below 1.o mg/L. In addition, the proposed WWTP upgrades will include
chemical addition in the primary clarifiers to support chemical phosphorus precipitation and tertiary filtration to
provide particulate TP removal. Therefore, Novozymes proposes an effluent BAT limit of i.o mg/L TP.
Table 10.2. Proposed TN and TP BAT Limits
i Rodrigo F. Bueno, Roque P. Piveli, Fabio Campos & Pedro A. Sobrinho (2018) Simultaneous nitrification
and denitrification in the activated sludge systems of continuous flow, Environmental Technology, 39:20,
2641-2652, DOI: 10.108o/o95()3330.2017.1363820
ii Metcalf & Eddy Inc. (2003) Wastewater Engineering Treatment and Reuse (4th Ed). New York, NY:
Mc-Graw-Hill.
iii Knapp, L. A. (2014). Study of Process Control Strategies for Biological Nutrient Removal in an
Oxidation Ditch. Graduate Theses and Dissertations.
iv The International Waster Association. (2018, November 28). Coagulation and Flocculation in Water
and Wastewater Treatment. Retrieved from The International Water Association: Publishing:
https://www.iwapublishing.com/news/coagulation-and-flocculation-water-and-wastewater-treatment
Dewberry Novozymes North America, Inc. I Best Available Technology Analysis 133

Appendix A: Wastewater Irrigation
System Permit (Permit # WQ0002806)
www.dewberry.com

Water Resources
ENVIRONMENTAL QUALITY
June 8, 2017
FRED REIKOWSKY - SENIOR DIRECTOR OF PRODUCTION
NOVOZYMES NORTH AMERICA, INC.
77 PERRY CHAPEL CHURCH ROAD
FRANKLINTON, NORTH CAROLINA 27525
Dear Mr. Reikowsky:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Subject: Permit No. WQ0002806
Novozymes Franklin County
Facility
Wastewater Irrigation System
Franklin County
In accordance with your permit minor modification request received May 3, 2017, we are
forwarding herewith Permit No. WQ0002806 dated June 8, 2017, to Novozymes North America, Inc. for
the continued operation of the subject wastewater treatment and irrigation facilities.
The modifications to the subject permit are as follows:
1. Addition of two new Schedule Conditions because of the Corrective Action Plan conditionally
approved by the Division on January 31, 2017. The new Schedule Conditions are Conditions
1.3 and I.4.
2. Modifications in Attachment B to (1) Fields EJ9 and GF 1 have reductions of yearly maximum
irrigation rate to 0 in/yr; and (2) Field GF4 has a reduction of wetted acreage from 33.1 to 31.1
acres.
This permit shall be effective from the date of issuance until May 31, 2020, shall void Permit No.
WQ0002806 issued dune 25, 2015, and shall be subject to the conditions and limitations as specified therein.
Please pay particular attention to the monitoring requirements listed in Attachments A, B and C for they
may differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
Please note the following permit conditions are new since the last permit issuance dated June
25, 2015-
➢ Condition I.3. —Twenty-one (21) new wells to be added.
➢ Condition I.4. — Overall capacity reduction from 30 in/yr to 8.5 in/yr.
➢ Attachment B — Fields EJ9 and GF4 have loading rates reduced from 30 in/yr to 0 in/yr; and
the net wetted area of Field GF4 is reduced from 33.1 acres to 31.1 acres.
­' 'Nothing Compares_,.
State of North Carolina I Environmental Quality j Water Resources I Water Quality Permitting I Non -Discharge Permitting
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-807-6332

Mr. Fred Reikowsky
June 8, 2017
Page 2 of 2
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding.
If you need additional information concerning this permit, please contact Troy Doby at (919) 807-
6336 or troy.dobygncdenr.gov.
Sincerely,
S. Jay Zimmerman, P.G., Director
Division of Water Resources
cc: Franklin County Health Department (Electronic Copy)
Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
Novozymes North America, Inc.
Franklin County
FOR THE
operation of an extended aeration wastewater treatment facility with nutrient removal capability,
discharging to the Franklin County POTW as permitted by the County and to an average 700,000 gallon
per day (GPD) wastewater irrigation facility consisting of the:
continued operation of a collection system consisting of: approximately 1,335 linear feet (LF) of 8-inch
gravity sewer; approximately 1,600 LF of 4-inch gravity sewer; approximately 705 LF of 3-inch force main;
approximately 9 LF of 3-inch wastewater collection piping to allow the collection of food preparation
wastewater a 112,800 gallon primary clarifier; and all associated piping, valves, controls, and
appurtenances; the
continued operation of: a 2,100 gallon concrete wet well and approximately 900 LF of 8-inch force main
and conversion of one existing 300 gallons per minute (GPM) pump to transfer primary clarifier effluent to
the concrete weir box receiving a mixture of high -strength wastewater and recycled activated sludge and
serving basins TO and T02; and all associated piping, valves, controls, and appurtenances; the
continued operation of: an influent flow meter and sampler for Lagoon No.1, the existing 4.7 million gallon
(MG) aeration basin, and operation of the Biolac diffused aeration system in Lagoon No.1 which is supplied
air by three 200 horsepower (hp) blowers an approximate 185,000 gallon anoxic zone; a floating baffle
curtain to physically separate the anoxic and aerobic zones, which shall be installed at the Permittee's
discretion; an aerobic zone with a relocated 1,920 gallon per minute (GPM) pump for internal recirculation,
and a motorized weir gate; and all associated piping, valves, controls, and appurtenances; the
continued operation of an anaerobic treatment system consisting of a 400,000 gallon covered pre -
acidification tank (PAT) which is supplied by two 700 GPM feed pumps and a 3,500 GPM centrifugal jet
mix pump; a 24,000 gallon covered recirculation tank (RT tank) with two 900 GPM centrifugal feed pumps
and 1,100 GPM recirculation/mixing pumps; a 208,000 gallon covered internal recirculation anaerobic
reactor (IC Reactor) with three heat exchangers; a bulk lime 6,350 gallon storage and metering tank for pH
and alkalinity adjustment for process control in the PAT, IC/RT and T02. The anaerobic treatment system
may be used at the discretion of the Permittee to replace or reduce the treatment load on Lagoon No. 1; and
all associated piping, valves, controls, and appurtenances; the
WQ0002806 Version 3.1 Shell Version 151201 Page I of 12

continued operation of. a 564,000 gallon secondary clarifier and associated pumps (A pit:. return sludge
pumps, B pit: waste sludge pumps, and C pit: effluent pumps) with approximately 600 LF of 8-inch force
main; and all associated piping, valves, controls, and appurtenances; the
continued operation of. a 250,000 gallon aerated basin (T02) with coarse bubble diffusers, served by three
existing 200 hp centrifugal blowers; a 240,000 gallon aeration basin (TO1) with a diffused aeration system;
foam suppression systems for TO 1 and T02 served by a submersible pump and associated nozzles; a recycle
pump station with centrifugal recycle pumps; and all associated piping, valves, controls, and appurtenances;
the
continued operation of: a 6 MG storage lagoon (Lagoon No. 2); a 36 MG storage lagoon (Lagoon No. 3)
and associated pumps; a flow meter for waste storage; transfer of evaporator condensate from the plant
facilities directly to the wastewater storage Lagoon No. 2 without pretreatment in the aeration basin; and
all associated piping, valves, controls, and appurtenances; the
continued operation of: approximately 10,800 LF of 8-inch diameter force main to supply treated effluent
from Lagoon No. 3 to a phosphorus removal system prior to discharge to the Franklin County POTW; a 25
hp submersible pump located in the wet well at Lagoon No. 3; and approval for occasional bypass or
overflow from the phosphorous removal system into existing Lagoon No. 2; the transfer of groundwater
from a remediation system for use as cooling tower make-up and process water prior to being treated in the
existing wastewater treatment facility; and all associated piping, valves, controls, and appurtenances; and
the
continued operation of a wastewater irrigation system consisting of: 906.3 acres of spray irrigation fields
served by a 700 GPM irrigation pump; a 1,500 GPM irrigation pump; an 800 GPM pump; a center pivot
irrigation system; a reel type irrigation system with portable spray guns; approximately 1,320 LF of 6-inch
diameter force main; approximately 1,900 LF of 8-inch force main with hydrant connections;
approximately 1,375 LF of 12-inch irrigation piping with hydrant connections; approximately 15,500 LF
of 8-inch irrigation piping with hydrant connections; approximately 1,220 LF of 6-inch irrigation piping
with hydrant connections; 1,400 LF of 6-inch irrigation line, 3,800 LF of 8-inch irrigation line and twelve
6-inch hydrants serving the R.J. Journigan property and portions of the E.H. Journigan Farm; 5,400 LF of
6-inch irrigation line with 10 hydrants serving the Charles Goswick property; a center pivot serving Fields
W7 and W9 and a Model 8000 Valley Center Pivot system with a Nelson 100 end -gun providing 670 LF
of wetted area and 250 GPM to irrigation Farm 3, Field G2, and 2,600 LF of 6-inch irrigation piping and
seven 6-inch hydrants serving Novo Farm #2; two center pivot irrigation systems consisting of a Model
8000 Valley Center Pivot system with a Nelson 100 end -gun providing 1,194 LF of wetted area and 450
GPM, 950 LF of 6-inch irrigation piping, 10 LF of 8-inch irrigation piping, and five 6-inch hydrants serving
Novo Farm #3:, 2,000 LF of 6-inch irrigation piping, 4,200 LF of 8-inch irrigation line with 19 hydrants
and three areas to be irrigated by reel type sprinkler equipment serving the Novo Farm #4; temporary,
above -ground piping from the Novo Farm #2, Novo Farm 44, and the E.H. Journigan Farm piping systems
serving the William E. Pearce Farm; the remaining acreage of these listed fields will be handled by portable
irrigation equipment from existing irrigation piping; and all associated piping, valves, controls, and
appurtenances;
to serve the Novozymes North America, Inc. Franklin County Facility, with no discharge of wastes to
surface waters, pursuant to the application received May 3, 2017, and in conformity with the project plans,
specifications, and other supporting data subsequently filed and approved by the Department of
.Environmental Quality and considered a part of this permit.
This permit shall be effective from the date of issuance until May 31, 2020, shall void Permit No.
WQ0002806 issued June 25, 2015, and shall be subject to the following specified conditions and
limitations:
WQ0002806 Version 3.1 Shell Version 151201 Page 2 of 12

I. SCHEDULES
Upon completion of construction and prior to operation of this permitted facility, a certification
(attached) shall be submitted from a licensed North Carolina Professional Engineer certifying that the
permitted facility has been installed in accordance with this permit, Division approved plans and
specifications, and other supporting documentation, including the location of all monitoring wells as
applicable. If this project is to be completed in phases and partially certified, the Permittee shall retain
the responsibility to track further construction approved under the same permit, and shall provide a
final certificate of completion once the entire project has been completed. Mail the Certification to the
Division of Water Resources, Water Quality Permitting Section, 1617 Mail Service Center, Raleigh,
NC 27699-1617. [15A NCAC 02T .0116(a)]
2. The Raleigh Regional Office, telephone number [phone], shall be notified at least 48 hours in
advance (excluding weekends and holidays) of operation of the installed facilities such that an in -place
inspection can be made. Notification to the regional supervisor shall be made from 8:00 a.m. until 5:00
p.m. on Monday through Friday, excluding State Holidays. [15A NCAC 02T ,0108(b)(2)]
3. Per the Corrective Action Plan conditionally approved by the Division on January 31, 2017, the
Permittee shall submit a request for modification to include twenty-one (21) new compliance
monitoring wells upon completion of installation and commissioning. (Anticipated completion in
September 2017). [15A NCAC 02T .0108(b)(2)]
4. Per the Corrective Action Plan conditionally approved by the Division on January 31, 2017, the
Permittee shall submit a request for modification for the overall capacity reduction of the facility from
30 in/yr to 8.5 in/yr upon receipt of a direct discharge permit and construction and commissioning of
the upgraded process wastewater treatment facility. (Anticipated completion at the end of Quarter 1,
2019). [15A NCAC 02T .0108(b)(2)]
5. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application.
[15A NCAC 02T .0105(d), 02T .0106, 02T ,0109, 02T .0115(c)]
II. PERFORMANCE STANDARDS
The subject non -discharge facilities shall be effectively maintained and operated at all times so there is
no discharge to surface waters, nor any contravention of groundwater or surface water standards. In
the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due
to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate the
effluent, the Permittee shall take immediate corrective actions including Division required actions, such
as the construction of additional or replacement wastewater treatment or irrigation facilities. [G.S. 143-
215.1, 143-213.3(a)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [ 15A NCAC 02B .0200, 02L .0100]
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C .0108]
WQ0002806 Version 3.1 Shell Version 151201 Page 3 of 12

4. The wastewater collection facilities shall be properly maintained and operated at all times. The
Permittee shall maintain compliance with an individual system -wide collection system permit for the
operation and maintenance of these facilities in accordance with 15A NCAC 02T .0400. If an
individual permit is not required, the following performance criteria shall be met:
a. The sewer system shall be effectively maintained and operated at all times to prevent discharge to
land or surface waters, and any contravention of groundwater or surface water standards.
b. A map of the sewer system shall be developed and actively maintained.
c. An operation and maintenance plan shall be developed, implemented and maintained.
d. Pump stations not connected to a telemetry system shall be inspected every day (i.e., 3 65 days per
year). Pump stations connected to a telemetry system shall be inspected at least once per week.
e. High -priority sewers shall be inspected at least once every six months.
f. A general observation of the entire sewer system shall be conducted at least once per year.
g. Overflows and bypasses shall be reported to the Raleigh Regional Office in accordance with 15A
NCAC 02B .0506(a), and public notice shall be provided as required per North Carolina General
Statute § 143 -215.1 C.
h. A grease control program shall be developed, implemented and maintained.
i. Right-of-ways and easements shall be maintained.
Inspection and maintenance records for Conditions IIA.a. through IIA.i. shall be maintained for a
period of at least three years, except for Conditions IL4.b. and 11.4.c., which shall be maintained
for the life of the system.
[15A NCAC 02T .0403]
5. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.0108(b)(1), 02T .0505(b)]
6. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T .0505(c), 02T .0505(n)]
7. This disposal system was individually permitted prior to December 30, 1983; therefore, the compliance
boundary is established at either 500 feet from the effluent disposal area, or at the property boundary,
whichever is closest to the effluent disposal area. An exceedance of groundwater standards at or beyond
the compliance boundary is subject to remediation action according to 15A NCAC 02L .0106(d)(2) as
well as enforcement actions in accordance with North Carolina General Statute 143-215.6A through
143-215.6C. [15A NCAC 02L .0107]
8. In accordance with I SA NCAC 02L .0108, the review boundary is established midway between the
compliance boundary and the effluent disposal area. Any exceedance of groundwater standards at the
review boundary shall require action in accordance with 15A NCAC 02L .0106. [15A NCAC 02L
.0106, 02L .0108]
9. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary. [ I5A NCAC 02L .0107(c)]
10. In accordance with 15A NCAC 02L .0107(d), no wells, excluding Division approved monitoring wells,
shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L
.0107(g). [15A NCAC 02L .0107]
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11. Except as provided for in 15A NCAC 02L .0107(g), the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the Franklin
County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[15A NCAC 02L .0107(f)]
12. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for irrigation sites permitted under 15A NCAC 02H .0200 shall be as follows (all
distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 400 1
ii. Surface waters: 100
iii. Any well with exception of monitoring wells: 100
iv. Any property line: 1502
v. Public right of way. 50
i Per pre-existing waivers, setbacks to habitable residences or places of public assembly under
separate ownership have been reduced for the following:
Site
Setback
Approval
Pearce Farm
200 feet to Field PF3
July 1, 1997
Goswick Farm
200 feet to Field GF1
November 17, 1995
2 Per pre-existing waivers, setbacks to property lines have been reduced for the following:
Site
Setback
Approval
Pearce Farm
50 feet to Field PF3
July 1, 1997
Goswick Farm
50 feet to Fields GF I, GF2, GF3 & GF4
November 17, 1995
Novozymes Farm 4
50 feet to Fields S2, S3 and S4
July 1, 1997
[ 15A NCAC 02H .02190)]
b. The setbacks for storage and treatment units permitted under 15A NCAC 02H .0200 shall be as
follows (all distances in feet):
i. Any well with exception of monitoring wells:
ii. Any property line:
[I 5A NCAC 0214 .02190)]
100
50
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c. The setbacks for the 250,000 gallon aerated flow equalization unit permitted under 15A NCAC
02T .0500 shall be as follows (all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 100
ii. Any private or public water supply source: 100
iii. Surface waters: 50
iv. Any well with exception of monitoring wells: 100
v. Any property line: 50
[I 5A NCAC 02T. 0506(b)]
HL OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater resulting
from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan,
which at a minimum shall include operational functions, maintenance schedules, safety measures and
a spill response plan. [15A NCAC 02T .0507]
2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or more
certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules. [ 15A NCAC 02T .0117]
A suitable year round vegetative cover shall be maintained at all times, such that crop health is
optimized, allows for even distribution of effluent and allows inspection of the irrigation system, [15A
NCAC 02T .0108(b)(1)]
4. Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites listed
in Attachment B. [15A NCAC 02T .0108(b)(1)]
5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff. [15A NCAC 02T .0108(b)(1)]
6. All irrigation equipment shall be tested and calibrated at least once per permit cycle. Calibration records
shall be maintained at the facility for a period of no less than five years, and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
7. Only effluent from Novozymes Franklin County Facility shall be irrigated on the sites listed in
Attachment B. [G.S. 143-215.1]
8. No automobiles or machinery shall be allowed on the irrigation sites except during equipment
installation or while maintenance is being performed. [15A NCAC 02T .0108(b)(1)]
J. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited. [ 15A NCAC
02T .0505(q)]
10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .I100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .0508. [ 15A NCAC 02T .0508, 02T .1100]
11. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited. [15A NCAC 02T .05050)]
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12. Freeboard in the Lagoon Nos. 1, 2 and 3 shall not be less than one foot at any time. [15A NCAC 02T
.0505(d)]
13. Gauges to monitor waste levels in Lagoon Nos. 1, 2 and 3 shall be provided. This gauge shall have
readily visible permanent markings, at inch or tenth of a foot increments, indicating the following
elevations: maximum liquid level at the top of the temporary liquid storage volume; minimum liquid
level at the bottom of the temporary liquid storage volume; and the lowest point on top of the dam.
[15A NCAC 02T .0108(b)(1)]
14. A protective vegetative cover shall be established and maintained on all earthen embankments (i.e.,
outside toe of embankment to maximum allowable temporary storage elevation on the inside of the
embankment), berms, pipe runs, erosion control areas, and surface water diversions. Trees, shrubs, and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankment areas shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T
.0108(b)(1)]
15. Wastewater irrigation fields with rock outcrops within the wetted area shall be properly buffered to
avoid irrigation on these rock outcrops. [15A NCAC 02T .0108(b)(1)]
16. If animal waste is applied to any of the wastewater irrigation fields, adequate protection shall be taken
to insure the animal waste is not washed off the site and the irrigation rate shall be reduced to an
appropriate level to ensure that agronomic rates are not exceeded for that field. [15A NCAC 02T
.0108(b)(1)]
17. Irrigation areas not under the Permittee's ownership (i.e., the 287.6 acres owned by R.J. Journigan,
Charles Goswick, E.H. Joumigan and William E. Pearce) shall not be used to provide additional
wastewater treatment and disposal capacity, and shall only be used to provide better operation of the
wastewater treatment and disposal system. [15A NCAC 02T .0108(b)(1)]
18. All water supply wells adjacent to the treatment or disposal areas shall be properly buffered or
permanently abandoned in accordance with 15A NCAC 02C .0113. If any of these water supply wells
are to be converted into monitoring wells in lieu of being abandoned, the wells must comply with the
15A NCAC 02C monitoring well requirements and be properly constructed to prevent the vertical
migration of any groundwater contaminants that maybe released. [15A NCAC 02T .0108(b)(1)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water analyses)
necessary to ensure groundwater and surface water protection shall be established, and an acceptable
sampling reporting schedule shall be followed. [15A NCAC 02T .0108(c)]
2. A Division certified laboratory shall conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters. [15A NCAC 02H .0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR.
The Permittee shall install and maintain an appropriate flow measurement device to ensure the accuracy
and reliability of flow measurement consistent with accepted engineering and scientific practices.
Selected flow measurement devices shall be capable of measuring flows with a maximum deviation of
less than ten percent from true flow; accurately calibrated at a minimum of once per year; and
maintained to ensure the accuracy of measurements is consistent with the selected device's accepted
capability. The Permittee shall maintain records of flow measurement device calibration on file for a
period of at least five years. At a minimum, documentation shall include:
a. Date of flow measurement device calibration,
b. Name of person performing calibration, and
c. Percent from true flow.
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[I5A NCAC 02T .0105(k)]
4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for
the parameters specified in Attachment A. [15A NCAC 02T .0108(c)]
5. The Permittee shall maintain adequate records tracking the amount of effluent irrigated. At a minimum,
these records shall include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings;
f. Continuous monthly and year-to-date loadings for any non -hydraulic parameter specifically
limited in Attachment B;
g. Weather conditions; and
h. Maintenance of cover crops.
[ 15A NCAC 02T .0108(c)]
6. Freeboard (i.e., waste level to the lowest embankment elevation) in Lagoon Nos, 1, 2, and 3 shall be
measured to the nearest inch or tenth of a foot, and recorded weekly. Weekly freeboard records shall
be maintained at the facility for a period of no less than five years, and shall be made available to the
Division upon request. [15A NCAC 02T .0108(c)]
Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and
IV.6.) on Form NDAR-1 for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the monitoring month, monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[I5A NCAC 02T .0105(1)]
A record shall be maintained of all residuals removed from this facility. This record shall be maintained
at the facility for a period of no less than five years, and shall be made available to the Division upon
request. At a minimum, this record shall include:
a. Name of the residuals hauler;
b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[I5A NCAC 02T .0108(b)(1)]
9. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a
period of no less than five years, and shall be made available to the Division. upon request. At a
minimum, this log shall include:
a. Date of calibration of flow measurement device;
b. Visuai observations of the plant and plant site; and
c. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections
and cleanings, etc.).
[I SA NCAC 02T .0108(b)(1)]
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10. Monitoring wells shall be sampled at the frequencies and for the parameters specified in Attachment
C. All mapping, well construction forms, well abandonment forms and monitoring data shall refer to
the permit number and the well nomenclature as provided in Attachment C. [15A NCAC 02T
.0105(m)]
11. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(m)]
12. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for a period
of no less than five years, and shall be made available to the Division upon request. At a minimum, the
Standard Soil Fertility Analysis shall include the following parameters:
Acidity
Exchangeable Sodium Percentage
Phosphorus
Base Saturation (by calculation)
Magnesium
Potassium
Calcium
Manganese
Sodium
Cation Exchange Capacity
Percent Humic Matter
Zinc
Copper
pH
[15A NCAC 02T .0108(c)]
13. Noncompliance Notification:
The Permittee shall report by telephone to the Raleigh Regional Office, telephone number (919) 791-
4200, as soon as possible, but in no case more than 24 hours, or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following:
a, Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Any emergency requiring immediate reporting (c.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure the problem does not recur. [15A NCAC 02T .0105(l), 02T .0108(b)(1)]
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V. INSPECTIONS
1. The Fermittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and irrigation facilities. [15A NCAC 02T .0108(b)]
2. The Permittee or their designee shall inspect the wastewater treatment and irrigation facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the
release of wastes to the environment, a threat to human health or a public nuisance. The Permittee shall
maintain an inspection log that includes, at a minimum, the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this
inspection log for a period of five years from the date of the inspection, and this log shall be made
available to the Division upon request. [15A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and irrigation facilities
permitted herein at any reasonable time for determining compliance with this permit; may inspect or
copy any records required to be maintained under the terms and conditions of this permit, and may
collect groundwater, surface water or leachate samples. [G.S. 143-21,5.3(a)(2)]
. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes. 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit shall become voidable if the permitted facilities are not constructed in accordance with the
conditions of this permit, the Division approved plans and specifications, and other supporting
documentation. [ 15A NCAC 02T .0110]
3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T .0105(n).
[G. S. 143-21.5.1 ]
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under General Permit NCG010000; any requirements pertaining to wetlands under 15A NCAC 02B
.0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter 143 of the
General Statutes. [15A NCAC 02T .0105(c)(6)]
In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner. [ 15A NCAC
02T .0104]
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities
permitted herein. [15ANCAC 02T .0108(b)(1)]
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority. [15A NCAC 02T
.01050)]
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8. This permit is subject to revocation or unilateral modification upon 60-day notice from the Division
Directo, in whole or part for the requirements listed in 15A NCAC 02T .0110. [ 15A NCAC 02T .0110]
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). [15A
NCAC 02T .01.20]
10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 8' day of June 2017
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Jay Zimmerman, P.G., Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0002806
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Permit No. WQ0002806 Wastewater Irrigation System
Novozymes North America, Inc. June 8, 2017
Novozymes Franklin County Facility Franklin County
ENGINEERING CERTIFICA 1rION
❑ Partial ❑ Final
In accordance with 15A NCAC 02T .0116, I, as
a duly registered Professional Engineer in the State of North Carolina, having the Permittee's authorization
to ❑ periodically ❑ weekly ❑ fully observe the construction of the permitted facility, hereby state to the
best of my abilities that due care and diligence was used in the observation of the construction, such that
the facility was built within substantial compliance and intent of this permit, the Division -approved plans
and specifications, and other supporting documentation.
❑ Any variation to this permit, the Division -approved plans and specifications, and other supporting
documentation has been documented in the attached as -built drawings, and shall serve as the
Permittee's minor modification request to amend the permit accordingly,
Provide a brief narrative description of any variations:
THE COMPLETED ENGINEERING CERTIFICATION, INCLUDING ALL SUPPORTING
INFORMATION AND MATERIALS, SHALL BE SENT TO THE FOLLOWING ADDRESS;
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service:
1617 MAIL SERVICE CENTER
By Courier/Special Delivery:
512 N. SALISBURY ST.
RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH, NORTH CAROLINA 27604
WQ0002806 Version 3.1 Shell Version 151201 Page 12 of 12

ATTACHMENT A — LIMITATIONS AND MONITORUNG RE, QUIEREP4ENTS
PPI 091 -- qNWTP Effluent
Permit Nu bey. Q4)002806 Version: 3.1
EFFLUENT C ARACTERISTtCS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PCS
Cade
Parameter Description
of
Measure
Measure
Monthly
Average
Monthly nthly
Geometric Mean
DailMinimum
y
1�<aaly l axirnAja i
Measi.9rem. ent
frequency
S4 ;'nple
Type
00310
BOD, 5-Day (20 °C)
mg/L
2 x Month
Grab
00916
Calcium, Total (as Ca)
mg/L
3 x Year t
—a Grab
50060
Chloride (as Cl)
mg/L
3 x Year
Grab m
50050
Flow, in Conduit or thru Treatment Plant
GPD
700,0002
_
Continuous
Recorder
00610
Nitrogen, Ammonia Total (as N)
mg/L
3 x Year
Grab
00625
Nitrogen, Kjeidahl, Total (as N)
mg/L�
2 x Month
Grab
00620
Nitrogen, Nitrate Total (as N)
mg/L
2 x Month
Grab
00600
Nitrogen, Total (as N)
mg/L
2 x Month
Grab
00400
pH
su
5 x Week
Grab
00665
Phosphorus, Total (as P)
mg/1,
�—
2 x Month
Grab
00931
Sodium Adsorption Ratio
ratio
3 x Year
Calculated
00929
Sodium, Total (as Na)
mg/L
3 x Year
Grab
70300
Solids, Total Dissolved —180 °C
mg/L
3 x Year
Grab
L 3 x Year sampling shall be conducted in March, July and November.
2. This flow value does not include the amount discharged to the Franklin County POTW.
WQ0002806 Vcrsio€t 3.1 Attachment A Pago 1 of 1

ATTACHMENT B - APPROVED LAND APPLICATION SITES AND LIMITATIONS
Novozymes North America, Inc. - Novozymes Y2-anidSn Ccuuty Facility
Permit Number. WQ0002806 Version: 3,1
IRRIGATION AREA, INFORMATION
APPLICATION LIMITATIONS
Field
®weer
County
Latitude
Longitude
- --
Net
Acreage
Dominant
-Soil Series
Parameter
- --
Hourly
Rate
Yearly
Max
30
Units
inches
EJ 1
Journigan, E H
Franklin
36-0844180
78.3845640
12.1
01284 - Non -Discharge Application Rate
EJ2
Journigan, E H
Franklin
36.07902"
78-3844690
T6
01284 - Non -Discharge Application Rate
30
inches
EJ3
Journigan, E H
Franklin
36.0765040
78.38437V
4.3
01284 - Non -Discharge Application Rate
30
inches
EM
Journigan, E H
,Franklin
36.0754660
78.3855630
4.3
01284--Non-Discharge Application Rate
30
inches
EJ5
Journigan, E H
Franklin
36-07293GO
78.384636"
8.8
01284-Non-Discharge Application Rate
30
inches
EJ6
Journigan, E H
Franklin
36.0797120
78.3831380
7.7
01284-Non-Discharge Application Rate
30
inches
EJ7
Journigan, E H
Franklin
36-0800000
78.381260
17
01284-Non-Discharge Application Rate
30
inches
EJ8
Journigan, E H
Franklin
36.0759080
78.3819500
33.6
01284 - Non -Discharge Application Rate
30
inches
E19
Journigan, E H
Franklin
36,072796"
78.3968340
6.6
01284 - Non -Discharge Application Rate
0
inches
G1
Novozymes North America, Inc.
Franklin
36.0838560
78.4007500
55.3
01284 - Non -Discharge Application Rate
30
inches
G2
Novozymes North America, Inc.
Franklin
36,0791160
78.4011780
40
01284 -Non-Discharge Application Rate
30
inches
G4A
Novozymes North America, Inc.
Franklin
36.0840530
78.3897460
31.5
01284 - Non -Discharge Application Rate
30
inches
G4B
Novozymes North America, Inc.
Franklin
36,0798460
78.389555"
36.9
01284 -Non-Discharge Application Rate
30
inches
G4C
Novozymes North America, Inc.
Franklin
36-075620
78.3893890
26.6
-
01284 -Non-Discharge Application Rate
30
inches
G5
Novozymes North America, Inc.
Franklin
36.0862230
78.3898170
5.3
01284 - Non -Discharge Application Rate
30
inches
G6A
Novozymes North America, Inc.
Franklin
36.0879130
78.389841"
7.5
01284 - Non -Discharge Application Rate
30
inches
G613
Novozymes North America, Inc.
Franklin
36.0881250
78.3911480
7.5
01284 - Non -Discharge Application Rate
30
inches
G7
Novozymes North America, Inc.
Franklin
36-0787510
78.3988490
7.9
01284 - Non -Discharge Application Rate
30
inches
GFI
Goswick, Charles
Franklin
36.0630550
78.3912670
9A
01284 - Non -Discharge Application Rate
0
inches
GF2
Goswick, Charles
Franklin
36.0664560
78.3938340
20,9
01284 - Non -Discharge Application Rate
30
inches
GF3
Goswick, Charles
Franklin
36.06757°
78.39219V
15A
01284 - Non -Discharge Application Rate
30
inches
GF4
Goswick, Charles
Franklin
36.0709130
78-3946660
31.1
01284 -Non-Discharge Application Rate
.30
inches
J1
Joiarnigan, IZJ
Franklin
36.0846480
78.3870120
12,9
01284-Non-Discharge Application Rate
30
inches
J2
Journigan, RJ
Franklin
36.0798080
78.3871070
28.8
1
01284-Non-Discharge Application Rate
30
inches
WQ0002806 Version 3.1 Attachwent 13 Page 1 0F3

Field
J3
Owner
Journigan, RJ
County
Franklin
;latitude
36.0749670
Longitude
g
78,3871550
Net
Acreage
12.7
Dominant
Soil Series
Parameter
01284 - Non -Discharge Application Rate
Hourly
Rate
Yearl y
Max
30
Units
inches
NI
Novozymes North America, Inc.
Franklin
36.1048620
78.4062940
71.6
01284-Non-Discharge Application Rate
30
inches
PF i
Pearce, William E
Franklin
36.0945210
78.396484°
4.2
01284 - Non -Discharge Application Rate
30
inches
PF2
Pearce, William E
Franklin
36.0927150
78.3961390
13.3
01284-Non-Discharge Application Rate
30
inches
PF3
Pearce, William E
Franklin
36.094924°
78.3934530
11.6
01284 - Non -Discharge Application Rate
30
inches
PF4
Pearce, William E
Franklin
36.093080
78.3932160
11.2
01284-Non-Discharge Application Rate
30
inches
PF5
Pearce, William E
Franklin
36.0845140
78.3835180
5.9
01284 -- Non -Discharge Application Rate
30
inches
PF6
Pearce, William E
Franklin
36.081306"
78.3811180
6.2
01284 -Non-Discharge Application Rate
30
inches
S1
Novozymes North America, Inc.
Franklin
36.0965180
78.396923"
20.9
01284-Non-Discharge Application Rate
30
inches
S2
Novozymes North America, Inc.
Franklin
36.0969020
78.393620
I4.6
01284 - Non -Discharge Application Rate
30
inches
S3
Novozymes North America, Inc.
Franklin
36,0996680
78.388700°
26.5
01284 --- Non -Discharge Application Rate
30
inches
S4
Novozymes North America, Inc.
Franklin
36.0999940
78.3955930
13.7
01284 - Non -Discharge Application Rate
30
inches
T2
Novozymes North America, Inc.
Franklin
36.1032010
78.4113W
6
01284 -Non-Discharge Application Rate
30
inches
VFI
Novozymes North America, Inc.
Franklin
36.098995°
78.4153910
46.9
01284-Non-Discharge Application Rate
30
inches
VF2
Novozymes North America, Inc.
Franklin
36.101050
78.4196930
48
01284 - Non -Discharge Application Rate
30
inches
VF3
Novozymes North America, Inc.
Franklin
36,1065420
78.4181480
16.6
01284 - Non -Discharge Application Rate
30
inches
VF4
Novozymes North America, Inc.
Franklin
36.1071180
78.4205250
7.5
01284 - Non -Discharge Application Rate
30
inches
VF5
Novozymes North America, Inc.
Franklin
36.1077710
78.4137750
5.5
01284 - Non -Discharge Application Rate
30
inches
W 1
Novozymes North America, Inc.
Franklin
36.0953850
78.4046240
8.7
01284 - Non -Discharge Application Rate
30
inches
W2
Novozymes North America, Inc.
Franklin
36.0952690
78.4028180
5.9
01284 -Non-Discharge Application Rate
30
inches
W3
Novozymes North America, Inc.
Franklin
36.0949430
78.3992530
7.4
01284 - Non -Discharge Application Rate
30
inches
W4
Novozymes North America, Inc.
Franklin
36.0931380
78.4002990
16
01284 - Non -Discharge Application Rate
30
inches
W5
Novozymes North America, Inc.
Franklin
36.093810
78.4055750
5.3
01284 -Non-Discharge Application Rate
30
inches
W6
Novozymes North America, Inc.
Franklin
36.0949810
78.408261°
10.5
01284 -Non-Discharge Application Rate
30
inches
W7
Novozymes North America, Inc.
Franklin
36.0967680
78.4079040
9.6
01284 -Non-Discharge Application Rate
30
inches
W8
Novozymes North America, Inc.
Franklin
36,0974010
78.403151°
4.1
01284 -Non-Discharge Application Rate
30
inches
W9
Novozymes North America, Inc.
Franklin
36.0985150
78.4049810
38.8
01284 - Nan -Discharge Application Rate
30
inches
W10
Novozymes North America, Inc.
Franklin
36.0973820
78.39932V
16.1
01284 -Non-Discharge Application Rate
30
inches
Q0002806 Version 3.1 Attachment D Page 2 ol'3

Totals 904.30
WQ0002806 Vorsion 3.1 A tachment B Pagc 3 of

M �
-.

ATTACHMENT C — GROUNDWATER 140 ZTORING AND LIMITATIONS
i Onitoring wells; MW-1, W-2, IWW-3, 11 '-11, MW-12, MW-13, M -14, W-15, NM-M, l VV-17, MW--18, V-19, W-y24, I�ft -2�, I-22,1�'� d
23, iQ W-24. and MW-25
GROUNDWATER CHARACTERISTICS ERISTICS
GROUNDWATER STANDARDS
Daily Maximum
� — _ MONITORING REQUIREMENTS -
Frequency Measurement Sample Type Footnotes
PCS Code
Parameter Description
00680
Carbon, Tot Organic (TOC)
mgfL
l
3 x Year Grab 1,4
00940
Chloride (as Cl)
250 mg11,
3 x Year Grab 1
01055
Manganese, Total (as Mn)
0.05
mg/L
3 x Year
Grab
l
00610
Nitrogen, Ammonia Total (as N)
1.5
mg/L
3 x Year
Grab
� � 1
00620
Nitrogen, Nitrate Total (as N)
10
mg/L
3 x Year
Grab
1
00400
pH
6.5-8.5
su
3 x Year
Grab
1,2
00665
Phosphorus, Total (as P)
mg/L
3 x Year
Grab
1
70300
Solids, Total Dissolved — 180 °C
500
mg/L
3 x Year
Grab
1
00945
Sulfate, Total (as SO4)
250
mg/L
3 x Year
Grab
1
82546
Water level, distance from measuring point
ft
3 x Year
—E---
Calculated
1, 2, 3
--
3 x Year monitoring shall be conducted in March, July & November; annual monitoring shall be conducted every November.
2. The measurement of water levels shall be made prior to purging the wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH shall be made after purging and prior to sampling for the remaining parameters.
3. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for Each monitoring well. The measuring points (top of
casing) of all monitoring wells shall be surveyed relative to a common datum.
4. If TOC concentrations greater than 10 mgfL are detected in any downgradient monitoring well, additional sampling and analysis must be conducted to identify the individual constituents comprising
this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the naturally occurring TOC
concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
5. Monitoring wells shall be reported consistent with the nomenclature and location information provided in this attachment.
6. A Corrective Action Plan was conditionally accepted by the Division on January 31, 2017, See Condition 1.3.
WQ0002806 Version 3.1 Attachinent C Page 1 of l

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Field G7
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Field G6B Farm 3
Field G6A
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Field A
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Field G field EA
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Field PF5
Pearce Farm
Field PF6
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Field EJ5
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Farm 6
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Appendix B: Industrial User
Pretreatment Permit (Permit # 0112)
www.dewberry.com

Franklin County Public Utilities
Control Authority and/or Municipality
PERMIT
Industrial User Pretreatment Permit (IUP)
To Discharge Wastewater Linder the
Industrial Pretreatment Program
0112
lUP Number
N/A
40 CFR Categorytif Applicable)
In compliance with the provisions of North Carolina General Statute 143-215.1, any
applicable federal categorical pretreatment regulations, all other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Control Authority and/or Municipality Sewer Use Ordinance. The
following Industry hereafter referred to by name or as the permittee:
Induslry name, permitlee-
Novoz mes NA, Inc. (NZNA)
Facility Located at Street Address
77 Perry Chapel Church Road - P. O. Box 575
City
Franklinton
Stale, Zip
North Carolina 27525
is hereby authorized to discharge wastewater from the facility located at the above listed
address into the sanitary sewer collection system and the wastewater treatment facility of
the Control Authoritv and/or Municipality also known as the POTW listed below:
IVP Control Aulhority and/or Mumcipality WWTP name:
Franklin County Public Utilities
NPOES Number:
NCO069311
VAVTP Address:
1099 Lane Store Road
city, State, Zip
Franklinton, NC 27525
in accordance with effluent limitations, monitoring requirements, and all other conditions
set forth in Parts I, II, and III of this Industrial User Pretreatment Permit (IUP).
Effective date, this permit and the authorization to discharge shall become effective at midnight on this date:
11/9/2015
Expiration [fate, this permit and the authorization to discharge shall expire at midnight on this date:
9/22/2023
Sig Lure Date signed
Chris ❑ohe Director Public Utilities

Industrial User Pretreatment Permit JUP)
PART I
Specific Conditions
IUP, PART I, OUTLINE:
A.} IUP Basic Information
B.) 1UP Modification History
C.) Authorization Staternent
D7) Description of Discharges
E.) Schematic and Monitoring. Locations
F.) Effluent LirniB & Monitoring Requirements
C:} Definitions and Limit. Page(s) Notes
A It IP Rncir...Inl=nrmatinn-
Reeerving Control Authority & WWTP nanie :
POTW NPDES #:.
Franklin. County Public Utilities &, Frankliri Cotiwy ww,rP
NCO0693 t 1
[UP Nanie ;
I.UP Number :
NovozymeS.NA, Inc.
0.t 12
I U P EfNet ive date :
Pipe Num6ixs. Jist all regulated pipes-
i I1912D:18
OD 1
1UP Expiration slate :
[UP 40 CFR H.(if applicable), or NIA:
9/22/2023
NIA
B. IUP History:
2

Industrial User Pretreatment Permit JUP)
PART I
Speeffic Uonditions.
Renewal or
Effective Date. Modification Description of changes over previous IUP
11191261:8 ReriewaE . .
Tncreasednitri geii'"d. pl ospfiorgi s; limits
•:: C€angetl.tn uriiforin:atxior.al'irnits
Updated `5cl a natics flow::diagrairi :;and,treatinent processes.. o match
�urrenf::setiip
e.:: Added speciaT:cgndtiolz 24.f6r sltiiige: narlageni... plan.
$1912U15: Modified mass limits for total nitrogen discharge. to the Pt7TW.
• Changed phosphorous from a concentration based lirnit to a mass based
limit
■ Added penalty clause. giving the PO.TW director.authority to mvokeor
curtail permission to.discharge in the event Iimits are. violated.
• Modified definitions page
• Streatxilined :references to PDTW and the. S.UU throughout permit
• Reduce ammonia iimit.from 40 MyL to seasonal limits.
121231201.4 Modified Winter: Weekly average 29.4 mgIL,.Monthly average 10.0 mgll.
Summer: Weekly average 15..0 mgIL,.Manthly :average Sd ma1L.
• Change ammonia FREQUENCY.to Weekly
■ Remove.testing requirement for acrolein, acrylonitrile,
2,4 dinitrnphenol and 2..methyl 4.,.6 dinitrophe.nol.
• FLOW limit increase from 0.400 to 0.525 GPD.
8/08/2014 Modified 6 Sodium limit iiierease from 20,294 lbs. nerriionth to 50,608 lbs, per
month
■ Copper limit increase from .0'03. mgll to 0.05 mglt
R. Potassium limit stays at 65,956 tbs. per month
311712�14 Monthly average limit on.Potassi ui; 65,956 lbs pec month = 650rh-/I.at
Modified 400000. PD.
• Monthly average limit on Sodium...20,?94lbs, per month = 200 mgll at
4.001060 GPI7.
• Seasonal .Iimit from. October 31 toAprii 1 for Turbidity monitor Weekly
with Monthly average limit:cif t5 NTU's.
3

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
912212013 Renewal Removed Turbidity, Chlorine. and Daily Maximum l imits. Increased
Copper to 0.03 mgll.. Changed frequency of Temperature to Quarterly,
TSS and Alkaliniity. to Monthly. Now parameters-..acrolein and
acrylonitrile at 200..ug/L, 2,4 dinitrophenol and 2 methyl.4,6
dinitrophenol. at 500 ugll, , .and antimony at i mg1L as per NPDFS
Permit NC.00693.1 1 Part: III Other.RequiremenLs Section C. a.
Typographically error:oa.limits pages corrected
11/14/201.1 Modified Incremental FLOW increase: 0.325 MGD starting. l V11201:2 increase to
0.400 MGD starting f2111201.2. Reduce CD (cadmium) limit from 0.01:2
to 0.008 mg11... Reduce. CU (copper) limit from 0.045 to U.030 .ing/l.
Reduce ZN (zinc) limit from 0.480 to 0.4 mol Reduce monitoring
frequency to..quartedy for the Following parameters: AG (silver), CN.
(cyanide), 13OD5, NH3 (ammonia); CL (chlorine), and AL (aluminum).
11/112012 Modified
Replace limit for AG, and CL with MONITOR ❑ItiiLY:
61271201.1 Modified Incremental FLOW increase: 0.200 MGD starting 2115/?012.increase to
0.25 MGD starting. 71112..01..2..Increase Copper (Cu) daily limit to 0..045.
mgll, ntonthly average 0.036.. mg1l. Increase Line (`Ln) daily. limit to 0.48
moll, rhonthly avcrage.0.38 mg/l.
51.912011. Modified Chlorine. should be listed as a grab not composite and Chlorine limit
change to.2.0 mglL
1.015109 Modified Total Phosphorus limit Monthly Average of 1:5 mgli.. DECREASING to
10..mg/L beginning, 1.1/9/201 1 then DECREASING to .5 mg1L
beginning, 1.11912011 Daily Max. 18 1 1216 respectively:
Frequency -Weekly by IUP
• FLOW _ daily maximum at .10.4 gpm
• Alkalinity •- Monitor Only Frequency Weekly by ILII'
Expiration Date.- from 1213 !/20 t 1 .to 9122120 13
09/22/08 Mod iFied .: Lim its page relax parameters zinc, clipper, `lead, nickel, silver, chlorine.
and TSS;.also changed sampling to "twice a month," Part III Special
Condition .2 Changed to `'meter shall have.. appropriate. preventive
maintenance performed.at least every 12.months ."
Permit Issued
C.. Authorisation Statement:.
1..)' The. Permittee is hereby authorized to discharge wastewater in accordance. with
the effluent limitations, monitoring requirements; and .all other conditions set
forth in this Industrial User Pretreatment Permit (IUP) into the sewer collection
system and wastewater. treatment. facility of the POTW.
2.) The. Permittee is. hereby authorized to continue operation of and discharge:
wastewater from the following; treatment or pretreatment facilities. These
facilities. must correspond to the treatment units listed nn both. the application
and inspection Forms.
4

List all'rreatment /mils:
Pretreatment
Industrial User Pretreatment Permit JUP)
PART I.
.Specific. Conditions
IU Treatment Units
.6. aerati n tank; anaerobic up .ffow.;reactor;
al centrifu ation Sediri er titian via primary.
g
yp11 Pro tectork';ard 17AF;for flocculation -wit
3.,) The Permittee is hereby authorized to,. if required by the. POTW and after
receiving Authorization to Construct (A. to C) from the POTW, construct and
operate additional pretreatment units as: needed to meet final. effluent
limitations.
D_) Description of IUP Discharges) .from all regulated pipes:
Pipe # 00 1 ; Description. of Discharge:
>1?racers<:water`firvrrr; aqu a tiiire was"ati
es'enz Tries residuals offs ecification
is < Men :sent 1
anctay'elarFe
--
er:a:
1 -I'd- "'€ orri>secoricia'' 'clazrfi re
;:.:;:
g p ;samplPprnt at F13IV) tleri'dscYiar ed is Pi e�0.- , Sv- s :.x iy
fettled out, removed, treater/. and Stored": See map on page 6 for specific locations.
E.) Schematic and Monitoring Locations:
The facility schernatic and description of monitoring location(s) given on Following pages
must show enough. detail such that someone unfamiliar with the facility could readily find
and identify the monitoring. location(s) and connection to the. sewer. It must. include. and
identify all. regulated pipes. Representative sampling for Pipe 40 1 may be taken from 2
sample points. Sample point A and/or sample point B as shown on PART I Specific
Conditions- Plant Site Layout Plan (page, 6).
5

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
"i-
m

Inclustrial User Pretreatment Permit
PART
Specific Conditions
w
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Industrial. User Pretreatment Permit OUP).
.PART I
Specific Conditions
Wl

Industrial User Pretreatment Permit JUP)
PART I
Specific Conditions
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Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
G. Definitions and Limit Pages notes.:
ln:addition to the definitions in the Franklin County Sewer Use Ordinance .(SUO), the
following definitions. and requirements apply:
!. Permit issuing authority means Franklin County Public Utilities
2. Division or DWR means the Division of Water Resources,.part of the
Department. of Environment and Natural. Resources.
3. EMC means the North Carolina Environmental Management Commission.
4_ POTW (Publicly Owned 'Treatment Works).means Franklin County Public
utilities
5. Act: of "the Act" the Federal Water Pollution Control Act, also. known as the
Clean Water Act,. as amended 33 USC 1251, et seq.
6. Continuous, for the purpose of flow monitoring, is a measure of discharge (low
from the facility which occurs without interruption throughout the operating hours
of the facility. Flow shall be monitored continually except for the infrequent
tunes when there may be no flow or for infrequent maintenance activities on the
flow device.
7. Grab sample for the monitoring requirements of this 1tJP, is defined nu single
"dip and take" sample collected at a representative point in the. discharge stream.
S. A composite sample, for monitoring requirements. of this.IUP; is defined as a
series of grab. samples collected at equal. time intervals during. the entire discharge
.period on the sampling. day (24 hours +1= 2 hours). The time interval shall be at
teast.every 15 minutes, approximately 100 ails. of gample and greater than 50
.samples per day. The sampling day shall be a typical production and discharge
day..
9. Daily Monitoring Frequency as specified in this lUP shall mean each day of
discharge.
10. 116 months Monitoring Frequency as. specified in this IV is defined as sampling
to be conducted during the irtonths of March and September.
I L Quarterly Monitoring frequency as specified in. this IUP is defined as.sampling to
be conducted quarterly as one 24-hour composite sampling period during the
months ofJanuary, April, July and October.
11

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
12. Monthly Monitoring Frequency as specified in this IUP is defined as samplinla to
be conducted mondily as one 24-hour composite samplin- period during all
twelve calendar months.
13: Weekly monitoring as specified in this l UP. is d6fitiod a§ .samplii g; to lie conducted
t Least once a week (defined as Sunday to Saturday} as nne' Z4 Hour composite
sarpliug`period:
1-4. An instantarieous, measurement as specified in. this I UP is defined as a single
reading, observation, or measurement.
12

Industrial User Pretreatment Permit QUP)
PART II
General Conditions
Outline. of PART I.I,
1.
Representative Sampling
1.6:
2.
Reporting
17.
3.
Test Procedures
18.
4.
Additional Monitoring: by
.1.9.
Perrnittee
5.
Duty to comply
20.
6.
Duty. to Mitigate
21.
7.
Facilities Operation, Bypass.
22.
8.
Removed substances
23.
9.
Upset Conditions
2.4.
10.
Right of Entry
25.
1. l ..
Availability of Records.:
26.
12.
Duty to provide information
27.
13.
Signatory Requirements
28.
14.
Toxic. Pollutants.
29.
15:
Civil acid Criminal Liability
3.0.
Representative SampIing
Federal and/or State Laws.
Penalties
Need to Halt or Reduce
Transferability
Property .Riglits
Severability
Modification, Revocation,
Termination.
Reapplication
Dilution Prohibition
Reports of Changed Conditions
Construction of pretreatment
facilities.
Reopener
Categorical Reopener
General Prohibitive Standards
Reports of Potential Problems
Samples and measurements taken as required. herein shalt be representative of the volume
and. nature of'the monitored discharge. .Ali samples shall be taken at the rnonita.ring points
specified in this permit and, unless otherwise specified, before the effluent joins or is
diluted by any other waste stream., body of water; 'or substance. Monitoring points shall
not be changed without notification to and approval by, the permit issuing authority.
2. Reporting
a.) Monitoring results obtained by the pertuittee shall be reported on forms
specified by the PDTw; postmarked no later than. the twentieth (20). day of the month
followh.ig the month in which the samples were taken. if no discharge occurs during a.
reporting period (herein defined as each calendar month) in which a sampling event was to
have occurred,, a form with.the .phrase "no discharge" shall be submitted. Copies of these
and all other reports required herein shall. be submitted to the POTW and shall be sent to
the following address:.
.Pretreatment Coordinator
Franklin County Public Utilities
1.63:0 US l l.wy I.
Youngsvi[le, NC 27.596
13

Industrial User Pretreatment Permit
PART II
General Conditions
b.) if the sampling performed by the permittee indicates a violation, the
permitteeshall notify. the .purW within 24.ho.urs of Ybecoming aware of the violation. The
.n pe ittee shall alsorepeat. the sampling and analysis. and submit the results of the repeat
analysis to the POTW within 30 days after becoming aware of the violation..
3. Test Procedures
Test. procedures for the analysis of pollutants shall be performed in accordance with the
techniques prescribed in 40 CFR part 136 and amendments thereto unless specified
otherwise in the monitoring conditions of thispermit.
4. Additional. Monitoring by Permittee
lithe permittee monitors any pollutant at the location(s) designated herein more frequently
than. required by this. permit, using approved analytical methods as specified above, the
results of such monitoring shall be. submitted to the POTW. The POTW may require more
.frequent monitoring. or the monitoring of other pollutants not. required in this peririit by
written notification.
5. Duty to.Comply
The permittee must comply with all conditions of this permit. Any permit noncompliarree
constitutes. a violation of the SUO and is grounds for possible enforcement action.
b. Duty to Mitigate - Prevention of Adverse Impact
The pennittee shall take all reasonable steps to minimize or prevent any discharge in
violation of this pen -nit which has a reasonable likelihood of adversely affecting human
health, the POTW; the waters receiving the POTW's discharge, or the environment.
7. Facilities Operation, Bypass
The permittee shall at all times maintain in good working orderand operate as. eft:iciently
as possible, all control .facilities or systems installed or used. by the permittee to achieve
compliance with the terms and conditions of this permit. Bypass of treatment facilities is:
prohibited except when approved in advance by the POTW. Bypass. approval . shall be-.
given only when such. bypass is in compliance with 40 CF'R 403.17.
S. Removed. Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or
control of wastewaters shall be disposed of in a manner such as. to prevent any pollutants
from such materials from entering the sewer system. The permittee is responsible for
assuring -its compliance with any requirements regarding the generation, treatment, storage,
and/or disposal of "I lazardous waste" as defined under the Federal Resource.Conservation
.and Recovery Act_.
9. Upset Conditions
14

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
An `'upset" means an. exceptional incident in which there is an unintentional and temporary
noncompliance with the categorical pretreatment standards because of factors beyond the
reasonable control of the penninee. An upset does not include noncompliance to the extent
caused by operational error, improperly designed or inadequate treatment facilities, lack of
preventative maintenance, or careless or improper operations.
An upset may constitute an affirmative defense for action brought for [he..noncomp]iance.
The permittee has the burden of proof to provide. evidence and demonstrate that none of
the factors specifically listed above were respons1We For the. noncompliance:
I0. Right of Entry
The permittee shall allow the staff of the State of North Carolina Division ,of Water
Resources, the Regional Administrator of -the Environmental Protection Agency,. the Staff
ofthe POTW, and/or their authorized representatives, upon the presentation of -credentials:
I. To enter upon the. permittee's premises where a real or potential discharge
is located or in which records are required to be. kept under the. terms and conditions
of this permit; and
Z. At reasonable .tiines to have access to and copy mcords.rcqu 1 red to be kept.
Linder the terms and conditions of this permit;. to inspect any monitoring equipment.
or monitoring. method required in this permit; and to sample any discharge of
pollutants.
1 L Availability of Records and Reports
The permittee shall retain records of all monitoring. information, including all calibration
and maintenance records as well as copies of reports and information used to complete. the.
application for this permit for at least three years. All records that pertain to matters that
are subject to any type of enforcement action small be retained and preserved by the
permittee until.alI enforcement activities have concluded and all periods of limitation with
respect to any and all. appeals have expired.
Except For data determined to be confidential under the SU-0, all reports. prepared in
accordancewith terms of this permit shall. be available for public inspection at the Control
Authority and/or Municipality. As required by the. SUO; effluent data shall. not be:
considered confidential.
l Z. Duty to Provide infonnation.
The permittee shall furnish to the Director of Public VWorks or his/her designees, within. a
reasonable time.; any information. which the Director, his/her designs; or the .Division of
15

fnd.ustrial User Pretreatment Permit
PART 11.
General Conditions
Water Resources may request to determine whether cause exists for modifying; revoking
and reissuing, or terminating this. permit or to determine compliance with this permit. The
permittee shall also furnish, upon request,. copies of records required to be kept by this
permit.
13.. Signatory Requirements.
All reports or: information submitted pursuant to the requirements of this permit must be
signed and certified by the Authorized Representative as defined under the:SUU. if tile.
designation of an Authorized Representative is no longer, accurate because a different.
individual or position has responsibility for the overall operation of the facility, or ov.eral.l
responsibility for environmental matters for the company; a new authorization satisfying
the requirements of this section must be submitted. to the POTW Director prior to or
together.with any reports to be signed by an authorized representative.
14. Toxic Pollutants
If a toxic. effluent standard or prohibition (ineluding any schedule of compliance specified.
in such effluent standard or prohibition)is established under Section.307(a) of the Federal.
Clean Water Act. for a toxic. pollutant which is present in. the discharge and such standard
'ar prohibition is more stringent than any limitation for such pollutant in this permit, this
permit may be revised or modified in accordance with the toxic. effluent standard or
prohibition and the perm.ittee so. natifwd.
15. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the perrnittee from civil or criminal.
penalties for noncompliance.
16. Federal and/or State Laws
Nothing in this .permit shall be construed to preclude the institution of any legal action or
relieve the perinittee from any responsibilities, Iiabilitfes, or penalties. established pursuant
to any applicable federal and/or state law or regulation.
1.7. Penalties
The SUQ County provides that any person who violates a permit condition. is subject to a
civil penalty not to exceed $25,000 dollars per day of such violation.
In addition, The PU`l'1N Director may for go.od.cauw revoke wastewater discharge permit
or permission to discharge for any of the following reasons:
(1) Failure to accurately report the wastewater constituents and characteristics
of the discharge;
(2) Failure to report significant. changes in operations, or wastewater
constituents and characteristics
(3) Refusal of reasonable access to the user's premises for the purpose of
inspection or monitoring; or,
(4) Violation of conditions. of the permit or permission to discharge, conditions
of the SUO, or any applicable state and federal regulations:
16

Industrial User Pretreatment Permit QUP)
PART II
General Conditions
Noncompliarit industrial users will be notified of the proposed termination of their
wastewater permit and will be offered an opportunity to demonstrate why the proposed
action should not be taken.
it is the responsibility of the holder of this permit to deliver pretreated wastewater within
the effluent limits prescribed in this permit. The POTW is not required to. accept any
wastewater which. contains effluent.Iimits in excess of such limits prescribed in.this permit.
Upon notice to the perm iCho lder, the POTW has the right and option to curtail .acceptance
of sewer flow from the permit holder whenever there has been a violation. of 'the effluent
limits of this permit, including delivery of sewer flow.by the permit holder that causes or
contributes to the POTW 'violating or potentially violating the. loading jimits imposed. on
the POTW for its.discharge at itsapproved location. Any curtailment shall be for a duration
and in a volume or amount, in the.sole discretion of the POTW, deemed sufficient for it to
remain incompliance with any laws imposed. on it or with agreements to which it is a party.
Should the POTW exercise its right and option to 'Impose curtailment on the holder of this
permit, the POTW may thereafter gradually or all at once resurne acceptance. of flow
provided. the permit holder hassatisfied the Pam that the holder is.able to discharge
within the effluent limits prescribed herein.
Under state law, (NCCS 143-215.6B), under certain circumstances it is a crime to violate
terms, conditions; or requirements of pretreatmen(perrnits. It is a crime to knowingly make.
any False statement, representation, or certification in any record or either document
submitted or required. to be maintained under this peen -it, including monitoring reports or
reports of compliance or noncompliance. These crimes are enforced at the prosecutorial
discretion of the: local District Attorney.
18. Need to Halt or Reduce not a Defense
It shall not be a defense for a.perm ittee. in: an. enforcement action that it would have been.
necessary to halt or reduce the permitted activity to maintain compliance with the:
conditions:ol: the perirrit.
1:9. Transferability
This permit. shall not be reassigned or transferred or sold to a new owner, new user,
different premises, or a new or changed operationwithout approval of the POTW.
20. Property Rights
This permit does not convey any property rights in either real or personal property,or any
exclusive privileges; nor does. it authorize any "injury to .private property or any invasion of
personal. rights, nor any infringement of Federal, State or local laws or regulations.
21. Severability
The. provisions of this permit are severable and, if any provision of this permit or the
application of any provision of this permit to any circumstance is held invalid, the
application of such provision to other. c ircurnstances and the remainder of this permit shall
not be affected thereby.
17

Industrial User Pretreatment Permit (][UP).
PART It
General Conditions
22. Permit Modification, Revocation, Termination
This permit may be modified, revoked and reissued or terminated with cause in accordance
to the requirements of the SUO and North Carolina. General Statute or implementing
regulations..
23. Re -Application for Permit Renewal
The permittee is responsible for. filing an application for reiSsuance of this permit at. least
180. days prior to its expiration date.
24. Dilution Prohibition
'rho permittee shall not increase the use of potable or process water:or in any other way
:attempt to dilute the discharge as a partial or complete subslitute for adequate treatrrient to
achieve compliance with the limitations contained in this permit:
25. Reports of Changed Conditions.
The permittee shall give notice to the POTW of any planned .significant changes to the
permittee's operations or system which rilight alter the nature, quality; or volume of its
wastewater at least 19O days before the change. The permittee shall not begin the changes
until receiving. written. approval from the Control Authority and/or Municipality. Also see
Part II, 30. below for additional reporting requirements for spil1/slug.1ssues.
25. Reports of Changed Conditions Continued
Significant changes may include butare.not limited to
(a) increases or decreases to production;
(b) increases in discharge of previously reported pollutants;
(c) discharge of pollutants not previously reported to: the. Control Authority
and/or Municipality;
(d) new or changed product lines;
(e) new or changed manufacturing processes and/or chemicals; or
(f) new or changed customers.
26. Construction
No construction o..f pretreatment facilities or additions thereto shall be begun until Final
Plans and Specifications have been submitted to the POTW and written approval and an
Authorization to Construct (A to C) have been issued.
2T Reopener
The permit shall be modified or, alternatively, revoked and reissued to comply with any
.applicable effluent standard or limitation for the control of any pollutant shown to.
contribute to toxicity of the. WWTP effluent or any pollutant that is otherwise limited by
l8

Industrial User Pretreatment Permit JUP)
PART II
General Conditions
thePOTW discharge permit. The permit as modified or reissued under this paragraph may
also :contain any other requirements of state or federal pretreatment regulations then
applicable..
28. Categorical. Reopener
This permit shall be inodified, or alternativety, revoked and reissued, to comply with any
applicable effluent. standard or limitation issued or approved. under Sections 302(b)(2)(C)
and. (1)), 304(b)(2), and 347(a)(2) of the Clean Water Act, if the effluent standard or
limitation so issued or approved:
l.) contains different conditions or is otherwise more stringent than any
effluent limitation. in this permit; or
2.) controls any pollutant not limited €n this permit.
The permit as modified or reissued under this paragraphshall also contain any other
requirements. of the Act then applicable:
29. General Prohibitive Standards.
The permitteeshall comply with the .general prohibitive discharge. standards. in 40 CFR.
4015 (a) and (b) of the Federal pretreatment regulations.
30. Potential Pt:obletns
The permitteeshall provide protection from accidental and slug discharges or prohibited.
materials and other. substances regulated by this permit. The permittee shall. also notify the
POTW immediately of any changes at its facility affecting the potential for spills and. other
accidental discharge, discharge of a non -routine, episodic. nature, anon -customary batch
discharge, or a sling load as defined in the. S[JO.
Additionally, the permittee.' shall notify by telephone the POTW immediately of all
discharges that could cause problems to the POTW, including any slag loadings as defined
in the SUO. If the permittee experiences such a discharge, they shall inform the POTW
immediately upon the first awareness of the commencement of the discharge_ Notification
shall include location of the discharge, type of waste, concentration and voluine if known
and corrective actions taken by the. permittee, A written tolls}w-up. report thereof shall be
Filed by the pennittee within five (5} days, unless waived by the POTW.
19

Industrial User Pretreatment Permit JUP)
Part III
5necial Conditions
1. Slug/Spill control Measures
The permittee shall provide protection from accidental and slug discharges of prohibited
materials and other substances regulated by this.perm.it. the plan shall include, but is not
limited to:
- description of discharge practices, including non- routine batch discharges,
description of. stored chemicals, procedures for. immediately notifying the POTW of
slug discharges. that would cause a violation of 40 CFR 403.5 (b), with procedures.
for follow up notification within 5. days, .and if necessary, procedures, and if
necessary, procedures to prevent adverse impact from accidental spills, including.
inspection and maintenance of storage areas, handling and transfer of materials;
loading and unloading operations, control of plant. site run --off: worker training
building of containment 'structure or equipment , measures for containing toxic
organic. pollutants (including solvents), and for measures and equipment for
emergency response..
In addition. to the requirements in .Part. 11, 30, the. Permittee shall maintain,. update and:
submit current revisions and versions of the Novozyrnes Safety:document named "Spill
On -Site" to the PQTW.
The periilittee shall provide updates to Franklin County as required by Part 11, 30, of this
1UP. Modifications to tfie measures shall be approved by Franklin County prior to.
installationlirriplementati6n. If a measure fails, the Control Authority shall be notified
within 24 hours.
2 5Iudge TVlanagement P°an
3. Flow Measurement Requirements
The permittee shall maintain appropriate discharge flow measurement devices and methods
consistent with approved scientific practices to ensure the accuracy and reliability of
measurements of the volume of monitored discharges. Devices installed shall be a
continuous recording flow meter capable of measuring. flows with a maximum deviation
of less than 10% from true discharge rates throughout the range. of expected discharge
volumes. The devices shall be. installed, calibrated, and maintained to ensure::accuracy. At
the time of issuance of the permit; this method consists of MAGNETIC FLOW METER.
The meter shall have appropriate preventative. maintenance performed at least every twelve
(12) months. Modifications to the flow teetering. equipment shall be approved by the.
20

Industrial User Pretreatment Permit JUP)
Part III
at Conditions
P01'W prior to installation. If a required flow measurement. device fails., Elie Control
Authority shall be notified within 24 hours.
4. Certified Laboratory Analysis
Pollutant. analysis. shall be: performed by a North Carolina Division of Water Resources
Certified Laboratory that is certified in the. analysis of the pollutant in. wastewater.
5. Laboratory Fees and Administrative: Charges /surcharges
The permittee shall be billed for all. Laboratory fees associated with Franklin County's
C.Qmpliance monitoring of the permittee. The permittee will be bitted a monthly
Administrative fee of $100.00. The. permittee will be surcharged for any overage of
allowable limits per the. S.UO.
6. Certified Operator
Pursuant to Chapter 90A-44 of north Carolina General Statutes, and upon classification of
the facility by the Certification Commission, the permittee shall employ a certified waste
water pretreatment plant operator in resporisibility charge: (ORC) :of the wastewater
treatment facilities. Such operator must hold a. certification of the type and grade
equivalent to, or greater that the. classification assigned to. the wastewater treatment.
.Facilities by the Certification Commission.. The.. permittee must also employ.a certified
backup.. operator. of the. appropriate type and grade to comply with the conditions of Title
15A, Chapter 8A .020. The ORC of the facility must visit. the wastewater facility as,
required; must properly manage and document daily operation arid. maintenance of the
facility; and must comply with all other conditions of Title 15A, Chapter .8A .0200. The
permittee, shall submit a letter designating the operator in responsible charge to the
Certification Commission or their des i6riee within thirty days after facility classification.
7. Attachment from NPI9FS NCO06931.1. Part III -- Other [requirements, Section.
C "Municipal Control of Pollutants from Industrial Users.,"
20

Industrial User Pretreatment Perm.it(JUP)
Part III
5 ecp ial Conditions
20

Industrial User Pretreatment Permit JUP}
Part III
Special Conditions
NPDES permit` Standard Conditions.
Page 15 of 1.8
Section H. Pufiliciv Ua.ned Treatment Works (POTW ]
All POMs must provide adequate notice to the Nreclor of the foIIowing [4.0 CFR i22A2(b)]:
1. Any new introduction ofpolluiants into th:e POTW front an indircct:discharger, regardless ofthe means of
transport, which would be. subject`ta section 361 or 3D6orCWA if it were directly.discharging those pdIIntattts;
and
2, .any substantial change in the volume or character aFpoliutants'heing introduced by an. ind ircmd isch arger as:
influent to that: POTW at the time of issuance pf the pennit.
3. For pttrposes.of this paragraph, adequate notice sha11 include information on (I') the quality and quantity of'effluent.
introduced into the POTW, and (2) any anticipated impact. thAt.may result. rrom the change of the quantity or
qua lity.of effluent to be. discharged hom.thc POTW.
Section C. Municipal Control of Pollutants from„ Industrial Users;
Effiucn[ limitations are list ed'in Pali 16fthis. permit: Other pollutants attributable to inputsfrom industrial Users
discharging to the POTW may be present in the Permittee's discharge. At such time as sufficient nfotmat[on
becomes available:to: establish limitations for such po.11utan[s,.this permit may be revised. to specify eftluenl
limitations for any a a]l.of such other pollutants in accordance with best practicable technology or water quality
standards.
2: Prohibited Discharges
a. The .Permittee shall*velop and enforce. their Pretreaunenl.Progranh to implement rite prohibition against the
introduction ❑fpollutaws or discharges into the waste treatment system orwaaste collectia4system. which .
cause at- cant ribute to Pass Tbsaugh:dr.Interference as defined. in I. A:NCAC 02H .0900'and 40 C FR 463. [40
CF.R 4o3.5(a)(1.))
h, The Penn ittee.shit II develop and enfaree their Pretreatment Program to implement the. prohibitions against the
introduction ofthe following wastes in the waste treatmenI or waste co11ec[ion. syste.tn [40 CFR.403,5(b)]:
0 ) PoIIutartta which..create a fire or explosion hazard in die POTW, including; but rat iiniifed. to,
wastestreams with a..closed cup Ra_shpaint orlass than: [40 degrees Fahrenheit or 60 degrees Centigrade.
using the test meihodsspecified.in 40 CFR 261? 1;
(2) Pollutants. which cause rarrosive strucrural damage to the POTW,.bul in no case discharges'With pH lower
than 5.6, un]ess.the works isspec i€icaily designed to accommodate such discharges;
(3) Solid or, viscous poi€utams in amounts which cause obstruction to the flow in: the PO.TW resulting in
Interference;.
(4) Any pollutant, inrludbig oxygen demanding pollutants (BOD, etc.) released. in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
(5) Heat in amounts which.wi11 i6..ibit binilogica€ activity in.the POTW resulting is Interfereace, but in na
case heat in such quantities that the temperature at the PdTW Treatment Plant exceeds 400C (1040F)
unless the. Division, upon request of the POTW, approves alternate temperattire Iitihits-,
(6) Petroleum oil, non -biodegradable cutting oil, or prcducts,;ofmineral oil origin in amounts that will cause
Interference or Pass Through;
(7). Po110tants which. resuIt in the .prescnce of [oxic. gases, .vapors;.or fumes within the POTW in a quantity that
may cause atute.worker health and safety problems;. or
(8) Any trucked. or hauled pollutants, except at discharge points designated by Ihe.POM
c. The Perm itte..e•AaIf investigate the.source of a discharges into the POTW, including slug loads and other
unusual discharges, which.have the potential to adver3ely impact: the Prtmittee's:Pretreatment Program and/or.
the operation of the POTW,
The Pe. rmittee shaft report sue h.discharges into the POTW'to the Director or the appropriate, Region 1 Office.
Any information shall be provided orally within 24 hours from the time the Perntittee became aware of the
circumstances. A written .submission shall also be provided within.5 days of the time the.Perniinee becomes
Version 10/310011
2[]

Industrial l User Pretreatment Permit JUP)
Part IIY
Special Conditions
NPOES. Permit Standard Conditions
Page 16 of I S.
aware of the cimunmstancea. The written submission shall contain a descriptioil .of the discharge; Ole
investigation into possible sources; the period o f t h e discharge, including exact dates and cities; if the
discharge has. notecased. the anticipated time it is expected 16 caniinue; and steps taken or planned to:red ticc,
cliniinate,.and prevent reoccurrencc or.the noncompliance,
3. With regard to the effluent requirements Iisted in Part I of this perniit, it may be necessary for the Perm ittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR. Pan 403) to ensure•compliance by
the Permittee.with all applicable effluent limitations. SucIt actions by the Perin ittee may be necessary regarding
so rite. or all of the industries discharging. to the mttnicipa1.systern
4.. The Permitfee .sha1) require. any Ind ustr'ial User ([U.) discharging to the P.O.TW .to meet Federal Pretreatment
Standards developed.under Section 307(bj of the Act as attended (which includes categorical standards and.
speciFw IocaI limits, best management practices and narratiVe requirements)..prior to accepting wastewater from
any Significant lrtdustrial User (SiU), the Penh ittee shall either develop and submit to the Divisiona new
Pretreatment Program or, as necessary; a,moditication ofan existing l'retir"tment Program, for approvai as
required under section D below as well as 15A NCAC 02IL0907(a) and (b). [40 CFR 122.44(j)(2)]
S. This permit shall be. modified; or alternatively, revoked and reissued, to. incorporate or modify an approved POTW
Pretreatment Program or to. include a cont pliance.schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of ilia CWA and implementing regulations.or by the requirements of the
approved State pretreatment progrant:.:as appropriate
Section D.. Pretreatment Prop -rams
Under authority. of sections 307 (b) and (c) and 402{b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina 0cneraI Statute 1437215.3(.14) and. implementing regulations. 15A NCAC 0 2 H ,0900,.and in accordaEice.
with: the approved pretreatment pro gram,.a1i pro visions. and rcguIaIions.conWned and referenced in the pretreatment
program. suhm itta I are an enforceable part of.this permit. (40 CFR I22A40)(2)]
The Perm ittee: shal I operate its approved pretreatment program in ac.ccrdance with Section 402(b)(8)..ofthe.CWA, 40.
CFR403,15A NCAC 02H .0900, and the legal authorities; policies,.procedures. and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof.. Such operation shad include but
not limited to the implementation of the following conditions and requkemenis. Terms not defined in. Part I or Part IV
of this permit are as defined in 15A NCAC 0 2 H .0903 and%40 CFR 403:3.
1. Saw& Use Ordinance (SUO)
The Permittee.shall maintain.adequate legal.authorito implement its approved pretreatment program: [ISA
NCAC 02H .090ty 3(b)(32), 0905 and .0906(b)(l); 40 CFR 403.8(f)(1) and 4.03.9(b)(1) and (2)].
2. Industrial Waste Survey (1WS)
The Permittee shall implement an I.WS consisting 0fthe survey of users of the POTW collection system or
treamtent plant, as required by 40 CM 403.8(f)(2)(i-lii) and 15A NCAC 02H .[i905 ]also 40 CFR l?2.44(j)(1)],
including identification of all lad ustria1.Users that may haire:an impact on the POTW and the character and amount.
6f06lhnants contributed io.the POTW by these industrial. Users'and identification of.those. Ind ustrial Users
meeting the definition of SR7. Where. the Perm ittee accepts waslewater front one or more satellite Pl:1TWs, the
IWS for the Permitlee shall address: all sate IIile POTW services areas, unless the pretreatment program hi those.
satellite service areas isadIninistered lit+a separate Perin ilice with an approved Here atment:Prograin, The.
Parm iaee shall sobin il a. summary. of its I W S activities to the Division:at least once every rive years; and as
required by the Division. The IWS submission shall include a sunmtary.of any investigations conducted under
paragraph C 2 c.. of this. Pail. [ I SA NCAC 02H .0903 (b)(1 3), ,0905 and .0906(h)(2); 40 CFR 403.8(fl(2) and 403.9]
3, Moniorine PIan
The Permitlee shall implement a Division -approved Monitoring Plan for.the collection of facility specific data to
be used ill a w=e ator treatment•platil 14eadv<orks Analysis (HWA).for the development of.speciric pretreatment.
Local limits. Effluentdata from the Plan shall be reported on the DMRs (as. required by Parts 11.D and iI.E.5.).. [l.5A.
NCAC 02H ,0903(h)(l6), .0906.(b)(3)and .0905.]
End of Permit
Version 43112011
20

Appendix C: Approved Corrective
Action Plan Correspondence
www.dewberry.com

Water Resources
ENVIRONMENTAL QUALITY
January 31, 2017
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Steve Stadehnan, PhD
Groundwater Manager/Specialist
Novozymes North America, Inc.
77 Perry Chapel Church Road
PO Box 576
Franklinton, NC 27525-0576
RE: Conditional Corrective Action Plan (CAP) Final Approval
Novozymes North America, Inc. (NZNA)
Permit No. W00002806 and WQ0003487
77 Perry Chapel Church Road
Franklinton, NC
Franklin County
Dear Dr. Stadelman:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
On July 16, 2015, the Raleigh Regional Office, Water Quality Regional Operations Section
received your proposed Corrective Action Plan (CAP) for the above -referenced site. Review and
conditional approval for this CAP was delayed in anticipation of legislation (HB 765), which contains
provisions to allow for monitored natural attenuation of groundwater at certain permitted facilities.
As described in Title 15A North Carolina Administrative Code, Subchapter 2L, Classifications and
Water Quality Standards Applicable to the Groundwaters of North Carolina (15A NCAC 2L), the
Division's final approval of a CAP is contingent upon consideration of public input received following
notification in accordance with 15A NCAC 2L .0114. Certified mail receipts were provided, showing proof
of notification to the property owners and occupants potentially affected by the approval of the proposed
CAP submitted pursuant to 15A NCAC 2L .0106(1), "using natural attenuation processes."
Based upon a review of the information submitted in the CAP and after considering any public
comments and the Raleigh Regional Office recommendations, I am hereby granting conditional approval
to implement the CAP. The Division's decision is based on the information submitted in the proposed CAP
and supporting documents, and is contingent upon the following conditions:
1. The NZNA-recommended approach is for selected area active remediation via
groundwater extraction associated with Farms 1 and 2 and monitored natural attenuation
State of North Carolina I Environmental Quality I Water Resources
512 N. Salisbury Street 11611 Mail Service Center I Raleigh NC 27699-1611
919.707,9000

(MNA) of the impacted groundwater found in association with Farms 3 and the Smith,
Pickrel, and Alston properties and adjoining NZNA properties. The details of the CAP
Phase I and Phase 1I are found in Sections 6.3-7.2 of the CAP on pages 36-44.
a. Focused ground water extraction includes the continued extraction of groundwater
via six (6) existing groundwater recovery wells located north of Farm 1, six (6)
proposed recovery wells on the east side of Farm 2, and eight (8) proposed
groundwater recovery wells on the north side of Farm 2. Further details on this are
available in the CAP Section 7.1.1.2 on page 40.
b. As discussed in Section 6.1.1, natural attenuation of impacted groundwater at
points beyond the compliance boundary will require a reduction in irrigation rates
primarily to reduce total dissolved solids (TDS) loading. Reduced irrigation rates
require an off -setting increase in direct discharge of treated wastewater.
2. The Monitoring Plan is discussed in Section 8.0, beginning on page 45 of the CAP. Tables
21 and 22 summarize the monitoring wells to be included in the groundwater monitoring
program by farm.
a. On Fart 1, Farm 2, and the Smith/Pickrel/Alston/NZNA Properties, all of the trend
monitoring wells and the background monitoring wells will be sampled for Nitrate -
Nitrogen and TDS annually. All of the new and existing compliance monitoring wells
will be sampled for Nitrate -Nitrogen and TDS semi-annually in the fast year, and
annually after the first year.
b. On the Joumigan and Goswick Farms where MNA is proposed as the remedial
strategy, NZNA proposes to monitor groundwater for 5 years, examine data collected,
and report the findings to DWR. The existing and new trend and background
monitoring wells on these properties will be sampled for Nitrate -Nitrogen and TDS
three times per year.
c. New monitoring wells will be installed on the following properties, as mapped in
Figures 2, 3, 4A, 4B, and 5:
i. Farm 1: 9 new monitoring wells
ii. Farm 2: 6 new monitoring wells
iii. Farm 3: 4 new monitoring wells
iv. Smith, Pickrel, Alston, and NZNA Properties: 2 new monitoring wells
v. Journigan Property: 3 new monitoring wells
vi. Goswick Property: 1 new monitoring well
d. Known or potential water supply wells in the NZNA vicinity are included in Table 12,
and Figures 7 and 8. NZNA proposes to conduct monitoring upgradient of the Bowers,
Burt, McNeil, and Goswick water supply wells as outlined in the CAP Section 8.1.
DWR may recommend including the sampling of these water supply wells if any of
the upgradient monitoring wells show increases in nitrates or TDS over two or more
sampling events.
The surface water assessment plan is outlined in Section 6.2 of the CAP. A surface water
monitoring plan will be prepared and issued upon completion of pilot testing and the
selection of the final remedial options. This CAP Phase 3 includes the development of full-
scale design, costs, and permitting of the corrective actions. Approval of this CAP is
conditional upon receipt of an NPDES permit to allow for the treatment and disposal of
contaminated groundwater, which is required to comply with conditions of 15A NCAC
02L .0106(e), and .0106(l)(1).
State of North Carolina I Environmental Quality I `Hater Resources
512 N. Salisbury Street 11611 Mail Service Center I Raleigh, NC 27699-1611
919.7079000

4. Approval of this CAP is conditional upon successful demonstration that NZNA can
demonstrate compliance with 15A NCAC .0106(l)(6) upon completion of the surface water
assessment plan outlined in Section 6.2 of the CAP.
Upon receipt of additional information by our office, you may be required to perform additional
monitoring, conduct additional site assessment activities, assess the performance of the ongoing corrective
action, and/or evaluate the technological and economic feasibility of implementing a new technology at the
subject site. If NZNA cannot meet any of the conditions described in Conditions 1 — 4 above, a new
Corrective Action Plan may be required to meet the requirements of 15A NCAC 02L .0106.
You are required by 15A NCAC 2L .0114(c) to notify all interested parties, as specified in
paragraph (b) of that rule, that approval of the CAP was granted by the Director. Notification is required
by certified mail and must be made within 30 days of receipt of the Director's decision.
The above referenced restrictions have been determined to be applicable to the site and NZNA is
hereby approved in conjunction with the CAP. A survey plat delineating the areas of contamination at the
site and containing the information required in § 143B - 279.10.
A report detailing the findings of the monitoring effort must be submitted to this office on or before
the last day of March, July, and November of each calendar year. Failure to adhere to the requirements of
the CAP and this approval letter may be considered to be a violation of the rules, subject to possible
enforcement action by the Division.
If you have any questions, please call Laura Robertson of the Raleigh Regional Office at 919-791-
4200.
Sincerely,
l
. Jay erman, P.G., Director
Division of Water Resources
cc: Franklin County Health Department
WQROS Central Files
Water Quality Permitting, Non -Discharge Unit
RRO files
Edmund Henriques, S&ME, Inc. 8646 W. Market St. Ste. 105, Greensboro, NC 2740
State of North Carolina I Environmental Quality I Water Resources
512 N. Salisbury Street 11611 Mail Service Center I Raleigh, NC 27699-1611
919.707.9000

Appendix D: DEQ December 14,
2016 BAT Correspondence Letter
www.dewberry.com

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Director
Water Resources
ENVIRONMENTAL QUALITY
December 14, 2016
Ms. Angela Walsh, Environmental and Utilities Operations Manager
Novozymes North America
PO Box 756
Franklinton, NC 27525
Subject: Second Request for Additional Information
NPDES Application NCO089621
Novozymes North America
Franklin County
Dear Ms. Walsh:
The Division received your additional information in response to our letter from August 9, 2016. The
additional information document referenced the Tar Pamlico Phase III Agreement as the basis for
justifying the proposed total nitrogen (TN) limit of 6 mg/l and total phosphorus (TP) limit of 1 mg/l. Page
15 of the agreement stated that new discharges of any kind receive 1 mg/1 TP effluent concentration limits
if they exceed 0.05 MGD permitted flow and additionally 6 mg/1 TN effluent concentration if they exceed
0.5 MGD permitted effluent flow. However, the Phase III agreement referenced in your letter is no longer
in effect and the Phase IV agreement approved in July 2015 no longer includes the referenced statement.
In addition, 15A NCAC 02B. 0229 states that TN and TP limits for new industrial discharges that have
permitted flows greater than 0.05 MGD which are not members of the Tar Pamlico Basin Association are
to be established based on BAT. TN and TP limits of 6 mg/l and 1 mg/l apply to domestic POTWs. The
application does not demonstrate or support that 6 mg/1 TN and 1 mg/1 TP are BAT for the proposed
Novozymes industrial discharge.
The permit application must be revised to include a complete BAT analysis. The development of limits
based on BAT is a case -by -case determination which is dependent upon the characteristics and treatability
of the specific industrial wastewater. The BAT analysis should include evaluation and discussion of the
industrial process involved, wastewater characteristics and treatability, wastewater treatment technologies
evaluated, proposed treatment and expected reductions, and a comparison of the cost of treatment
alternatives considered. Treatability tests must be conducted unless sufficient data from treatment of
similar wastes are available. For industrial wastewaters it is important to consider the complexity and the
nature of nitrogen compounds (i.e. refractory or non -refractory nitrogen components) and clearly
demonstrate that the industrial wastewater is amenable to treatment under the selected treatment
technology.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 807 6300

Page 12
Please reply within 60 days of receipt of this letter. If you have any questions or require more time to
complete the BAT analysis, please contact me at 919-807-6387 or email at teresa.rodri uezkncdenr..og_v.
Sincerely,
Teresa Rodriguez
NPDES Complex Permitting Unit
Division of Water Resources/NCDEQ
cc: NPDES Files
Katie Jones, P.E., Dewberry Engineers Inc.

Appendix E: Novozymes September
77 2018 Correspondence to the
Division
www.dewberry.com

Rethink Tomorrow
September 7.2O18
Via U.S. Mail and E-Mail
Jeffrey POuoart
Water Quality Permitting Section Chief
NCOEC)-DivisioDofVVaterResoVrces
1811 Mail Service Center
Raleigh, North Carolina 27099-1611
jeff.poupad@Ocdenr.g0V
JUUeGrzyb
SUperv|aor, Complex Permitting Unit
NCDEC)-Division ofWater Resources
1O11Mail Service Center
Raleigh, North Carolina 27689-1811
Jul|e.Grzyb@ncdenr,gov
Teresa Rodriguez
Complex Permitting Unit
NCDEC\ - Division of Water Resources
1811 Mail Service Center
Raleigh, North Carolina 27099-1611
[e-mail]
Mike Templeton
Water Quality Permitting Section
NCDEC>'Division ofWater Resources
1611 Mail Service Center
Raleigh, North Carolina 27698-1611
rnike.ta[np|[e-mail]
RE: NPDEG Permit Application NCO088621
Novozymem North America, Inc.
Franklin County
Dear K8c POUporL Ms. Grzvb, Me. Rodriguez, and Mr. Templeton:
This letter follows up on our meeting that was held On Fdday, August 24, 2018 and my letter to
you dated August 30.2018that memorialized the meeting. As forecast inmy August 30 letter,
on September5.2O18. representatives ofNovozymosNorth America, Inc. ("Novozymes°)and
Dewberry Engineering, Inc. ("Dewberry") met with Teresa Rodriguez, Mike Templeton, and Bing

novozymes
Rethmk Tomorrow
Boi of the Division of Water R85oVro8G (the "Division") to discuss the analysis of best available
technology economically achievable ("BAT)for nutrients related toNPOE8Permit Application
NCO088021 (the "Permit Application"). Specifically, the objective of the 800tenlbe[ 5 meeting
was to fully and finally agree upon the protocol and parameters for the BAT analysis and to
clarify the information requested by the Division in its letter dated JUD^ 19. 2018. Accordingly,
with regard tOthe BAT 8DG|ysiS. the 0VisioD. Novozynn8S, and Dewberry agreed as follows:
1. N0VozyrDes will prepare and submit to the OiVisk]O an updated. [evismd, and
compiled BAT 8O8haie document ("Revised BAT Analysis") that incorporates and
nap|eoee the previously submitted 8amt Available Technology /\nu/m;is dated
February 28. 2017 and Addendum to 8ea/ Available Technology Analysis dated
February 28'2O1&
2.The Revised BAT Analysis will focus on three different food -to -mass ratios (F:M)Mhat
represent the typical operation 'different��thrmw different treatment technologies; extended
aeration 0O /F:= 0.1\. conventional aeration (PK8 = 0.5). and high -rate aeration (F:K8 =
3. The Revised BAT Analysis will include:
a. @ clarification Vfthe interpretation oftraotabi|hvstudy data
i Novozymes will calculate and present effluent total limits
based on both maximum and 95Ih percentile data analysis for the
three technologies.
ii /#te[ review Of the data set, the Division agreed that data from
breatabi|ity study reactors M6-MI1 should beeliminated from the data
SEd used to evaluate a BAT total nitrogen |irnb. For completeness,
data from reactors K86-M11 will be included in the raw data appendix.
b. 8 description of 0 the current wastewater treatment system at the
NDvOzynneG facility-, and (i|) the proposed new wastewater treatment system
tobeinstalled inconjunction vvhhthe NPOEG penn\t, and adiscussion ofthe
performance of the current Svstanl and its inability to achieve enhanced
nitrogen nannVva/;
c. updated effluent data for the purpose of describing current system
performance;
d. a discussion of tneatabi|ity testing results with regards to effluent ornnnoO|a
(NH3) concentrations given that the permit limit for NH3 is expected to be 1.0
nog/L�
o. a discussion of the food -to -mass ratios as the design basis for tn8sdabi|ity
scale upfor each ofthe three technologies;
2
3024rmo,w

novozymes
Rethink Tomorrow
[ spreadsheet model outputs for each ofthe three technologies; and
g. Proposal of 8 BAT Total N (TN) limit based on the technology
represented by F:M of 0.5.
4. The comparative cost analysis in the Revised BAT Analysiswill compare the costs of
the three technologies and will include graphical analysis.
5. The reduction of the proposed BAT permit Unlk for TN by 1.0 rno/L would be
appropriate if reverse omrnom\o (RO) treatment is determined to be feasible by
Novozymes and proposed for the NPDES permit.
6. NovoZynneS VWU submit the Revised BAT Analysis to the Division on an expedited
Thank you again for your time and efforts regarding review and processing of the Permit
Application. Please let us know if there is anything you would like to add or clarify regarding the
contents of this summary of the meeting from September 5, 2018. We look forward to working
with the Division toward issuance of draft NPOEG permit.
Sincerely,
Angela . Walsh
Novozymea North America, Inc.
co Bill Lgne, DEQGeneral Counsel
Linda Culpepper, Division ofWater Resources OiRactuF
Mary Penny Kelley, Special Advisor, Office ofthe Governor
Andrew Hargrove, DEC>Assistant General Counsel
Jeff Manning, Classifications, Standards @^ Rules Review Branch
Connie Brower, C|assificationa, Standards & Rules Review Branch
ChrimVent@|oro. Classifications, Standards &Ru|eo Review Branch
Bing Bai, Complex Permitting Unit
Rick Bo|ioh' D\8/R - Raleigh Regional Office
Steve Tedder, TadderforrnConsulting
(all via e-mail only)

Appendix F: Novozymes' WWTP
Existing Site Layout
www.dewberry.com

GRAPHIC SCALE
1
1 1 inch = I60 tt
I 14A W"W'
DAF BUILDING
SECONDARY
ANAEROBIC
_
REACTOR
lk
rL
IRRIGATIONEFFLUENT
STORAGE LAGOON
,r
PRIMARY C
i
. � 4
�1
• L LAGOON
Je
JIL
f V J
4
L i
T ' 1
SOURCE: Aerial Image courtesy of Google Earth DATE TITLE SHEET NO.
Dewberr EXISTING SITE LAYOUT
'•' Dewberry Engineers Inc. y 11 /14/18 NOVOZYMES' WWTP
2610 WVCLIFF ROAD PROJ. NO. PROJECTSUITE FIG 1
RALEIGH, NC 27607 BAT ANALYSIS
ALEIG
PHONE: [phone]
FAX: [phone] 50107104 NOVOZYMES NORTH AMERICA

Appendix G: Novozymes' 2010 —
2014 Historical Wastewater Effluent
Data
www.dewberry.com

Appendix G
January 2010 - December 2014 Historical Effluent Data
Novozymes, Franklinton, NC
Month -Year
1z
COD °
Total
Phosphorus '
Calculated
Total Nitrogen
(TN)
3
Ammonia-N
Total Kjeldahl
3
Nitrogen (TKN)
3
Nitrate/Nitrite-N
mg/I
mg/I
mg/I
mg/I
mg/I
mg/I
Jan-2010
90.0
Feb-2010
120
Mar-2010
180
61
24
34
27
A r-2010
130
48
0.9
7.7
40
Ma -2010
240
Jun-2010
120
38
0.3
4.2
34
Jul-2010
150
21
0.2
6.3
14
Au -2010
180
9.7
0.2
9.3
0.36
Se -2010
180
17
0.5
12
5.2
Oct-2010
140
8.4
0.1
8.4
0.03
Nov-2010
130
8.1
0.7
7.1
1.0
Dec-2010
110
7.4
1.0
5.4
2.0
Jan-2011
28
0.1
5.5
22
Feb-2011
23
0.1
8.4
15
Mar-2011
58.3
1.5
13
1.5
11
1.6
A r-2011
63.5
0.8
19
0.1
7.4
11
Ma -2011
0.2
15
0.1
6.3
8.5
Jun-2011
1.0
15
0.2
6.8
8.2
J u I-2011
Au -2011
80.3
0.9
Se -2011
87.5
0.6
Oct-2011
0.2
Nov-2011
70.5
0.7
Dec-2011
55.0
0.8
Jan-2012
60.0
2.7
5.6
1.1
5.6
0.02
Feb-2012
76.0
3.6
9.3
0.1
7.7
1.6
Mar-2012
82.0
3.0
7.8
0.1
7.0
0.8
A r-2012
80.0
3.2
14
0.2
4.7
9.3
Ma -2012
74.0
3.6
18
0.1
5.6
12
Jun-2012
57.0
2.4
6.7
0.0
4.2
2.5
Jul-2012
63.5
3.1
4.7
0.1
4.7
0.01
Au -2012
72.0
2.5
7.8
1.1
6.5
1.3
Se -2012
61.0
2.7
6.9
0.1
4.3
2.6
Oct-2012
2.3
4.3
0.1
3.6
0.7
Nov-2012
59.0
2.5
9.7
0.0
4.7
5.0
Dec-2012
76.0
2.4
11
0.3
10
1.5
Jan-2013
63.0
2.5
Feb-2013
74.0
2.8
15
0.1
5.8
8.7
Mar-2013
2.1
A r-2013
59.0
2.9
7.6
0.2
4.4
3.2
Ma -2013
67.0
2.7
5.4
0.5
3.8
1.6
Jun-2013
74.0
2.1
Jul-2013
89.0
2.6
6.0
0.2
4.1
1.9
Au -2013
66.0
3.2
13
0.1
4.5
8.6
Se -2013
115
2.8
73
50
70
3.2
Oct-2013
100
3.5
15
0.1
6.6
8.3
Nov-2013
97.0
2.3
6.5
0.1
5.2
1.3
Dec-2013
110
2.9
14
3.5
12
1.5
Jan-2014
140
2.9
18
8.5
17
1.4
Feb-2014
140
3.3
14
2.4
11
3.0
11/14/2018 19 Dewberry.

Appendix G
January 2010 - December 2014 Historical Effluent Data
Novozymes, Franklinton, NC
Month -Year
1z
COD °
Total
Phosphorus '
Calculated
Total Nitrogen
(TN)
3
Ammonia-N
Total Kjeldahl
3
Nitrogen (TKN)
3
Nitrate/Nitrite-N
mg/I
mg/I
mg/I
mg/I
mg/I
mg/I
Mar-2014
2.6
11
0.3
8.7
2.1
A r-2014
95.0
1.7
7.8
0.1
7.1
0.7
Ma -2014
110
2.6
8.3
2.3
8.1
0.2
Jun-2014
95.0
2.3
9.2
1.4
7.0
2.2
Jul-2014
100
2.1
6.8
0.3
6.7
0.1
Au -2014
82.0
1.7
11
3.8
11
0.2
Se -2014
86.0
2.0
4.7
0.1
4.7
0.02
Oct-2014
94.0
2.4
6.8
1.1
6.8
0.04
Nov-2014
98.0
1.7
9.8
0.1
6.4
3.4
Dec-2014
190
1.9
39
1 18
39
0.04
11/14/2018 19 Dewberry

Appendix G
January 2010 - December 2014 Historical Effluent Data
Novozymes, Franklinton, NC
1z
Total
Calculated
3
Total Kjeldahl
3
Month -Year
COD °
Phosphorus '
Total Nitrogen
Ammonia-N
3
Nitrogen (TKN)
Nitrate/Nitrite-N
(TN)
mg/I
mg/I
mg/I
mg/I
mg/I
mg/I
2010 - 2014
Average
100
2.2
15
2.6
9.5
5.8
95th Percentile
180
3.5
45
15
28
25
MAX
240
3.6
73
50
70
40
Data presented in this table were analyzed by a certified lab or calculated if noted
'Data was taken from post tertiary (DAF) effluent
2COD data from 2010 was taken from Lagoon 3
3Data was taken from Lagoon 3
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