NC0089621_Comments on Draft Permit_20190506

Via U.S. Mail
NCDEQ/DWR
NPDES Permitting Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: Draft NPDES Permit — New Discharge
Permit NC0089621
Novozymes WWTP
Franklin County
Grade IV Biological WPSC
Dear NPDES Permitting Staff:
novozY mes•*
May 6, 2019
RECEIVED/NCDEQ/DWR
MAY 13 i1119
Water Quality
Permitting
On behalf of the permit applicant in the referenced matter, Novozymes North America, Inc.
("Novozymes"), this letter provides comments regarding Draft NPDES Permit NC0089621
(the "Draft Permit"). The public comment period for the Draft Permit opened on April 11,
2019 and will run through May 13, 2019.
Background
Novozymes is a global biotechnology company that makes commercial enzymes and biolog-
ical products used in a wide variety of commercial sectors, including baking, brewing, tex-
tiles, renewable energy, detergent, aquaculture, and wastewater treatment. Locally, Novo-
zymes is the largest private employer in Franklin County with approximately 660 manufactur-
ing jobs with excellent benefits in a county that is 85% rural. The company is based in Den-
mark and is known for its use of triple -bottom -line accounting which evaluates not just finan-
cial, but also social and environmental metrics that are important to the company's core val-
ues.' Operating in Franklinton since 1979, Novozymes makes enzymes using a fermenta-
tion process that generates wastewater that is treated on -site and then either sprayed on
farm fields near the facility or discharged to the Franklin County POTW.
See https://www.novozymes.com/en/about-us/sustainability.
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novozY mes•*
On May 31, 2016, Novozymes submitted an application for the Draft Permit for three im-
portant reasons. First, the NPDES permit will create a conjunctive wastewater system
whereby Novozymes can employ three different wastewater disposal methods: (i) discharge
to the Franklin County POTW; (ii) land application to farm fields; and (iii) direct discharge.
This conjunctive system will give the facility much needed operational flexibility, and
wastewater flows can be adjusted seasonally. Second, the NPDES permit will allow Novo-
zymes to expand the Franklinton facility and add sought-after manufacturing jobs in a rural
county. Third, the NPDES permit is required pursuant to the company's groundwater Cor-
rective Action Plan ("CAP") for Incident Number 86545 related to Permits W00002806 and
WQ0003487 that has been approved by the Director of Division of Water Resources (the
"Division"). The NPDES permit is a prerequisite to moving forward with the approved CAP
for groundwater, and Novozymes is eager to proceed with full CAP implementation. The
Draft Permit is an important step toward these goals.
Comments on Draft Permit Provisions
Novozymes has reviewed the Draft Permit and provides the following comments:
1. Effluent Limitations and Monitoring Requirements — Part I, Section A.0 )
a. For consistency with other local NPDES permit conditions for Grade IV facili-
ties, please revise the measurement frequency or BOD, TSS, NH3, Dissolved
Oxygen, pH, and Temperature from daily to 3 times per week. There is no
need or basis to deviate from the standard 3 times per week monitoring fre-
quency. Alternatively, Novozymes would request reporting of TSS, DO, pH
and Temperature using online instrumentation.
b. Please revise the Measurement Frequency for all metals to quarterly sampling
instead of monthly sampling. This frequency would be consistent with other
local NPDES permits.
c. Novozymes requests that a CBOD limit be used rather than the BOD 5-day
limit currently in the Draft Permit. This is appropriate for at least three rea-
sons. First, CBOD was used in the QUAL2K Cedar Creek model supporting
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novozY mes.*
the application, and consistency with the model should be maintained in the
final permit. Second, Novozymes is concerned that, given Novozymes
wastewater characteristics, inaccurate BOD readings could occur. As noted
in the EPA NPDES Permit Writers' Manual (September 2010), "basing permit
limits on CBOD5 instead of BOD5 eliminates the impact of nitrification on dis-
charge limitations and compliance determinations" and permit writers may
"use CBOD5 limitations in place of BOD.5 limitations to minimize false indica-
tions of poor facility performance as a result of nitrogenous oxygen demand."
See Section 5.1.3.5. Third, Novozymes is aware of multiple NPDES permits
issued by the Division for which CBOD was used in lieu of BOD limits, and
this is a common and appropriate parameter.
2. Instream Monitoring Requirements — Part I. Section A.(2)
a. Please delete the instream monitoring requirement for potassium. Potassium
will be controlled by the reverse osmosis (RO) system to be installed by No-
vozymes, and potassium levels in the effluent will be measured on a regular
basis. This is more than adequate to address potassium concerns.
b. Should Novozymes become a member of the Tar -Pamlico Basin Association
in the future, Novozymes requests that instream monitoring requirements for
Dissolved Oxygen, pH, Temperature, and Conductivity be deleted entirely.
3. Electronic Reporting — Part.l. Section AV)
Beginning on December 21, 2020, the Draft Permit requires electronic reporting of "Pre-
treatment Program Annual Reports" and "Clean Water Act Section 316(b) Annual Re-
ports." It appears these requirements were included in the Draft Permit in error. Novozymes
is not subject to Pretreatment Program reporting requirements (these requirements are for
POTWs). Additionally, Clean Water Act Section 316(b) applies to cooling water intake struc-
tures and thus is not relevant to Novozymes' NPDES permit application. Accordingly, please
delete the references to reporting requirements for "Pretreatment Program Annual Reports"
and "Clean Water Act Section 316(b) Annual Reports" from the Draft Permit.
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novozymes•*
4. Nutrient Offset Payment
As noted in the Division cover letter dated April 2, 2019 accompanying the Draft Permit, in
accordance with 15A N.C.A.C. 213.0229(c), Novozymes is required to make a nutrient offset
payment prior to issuance of the final permit and at each renewal. The amount of the offset
payment is determined by a formula set forth in the regulation that includes variables such as
permitted flow (in MGD) and the values of TN and TP based on a best available technology
economically achievable (BAT) analysis. As set out in the Draft Permit, these values are 2.0
MGD, TN of 8.8 mg/L and TP of 1.0 mg/L. Based on the formula using these values, and as
agreed with the Division, Novozymes will make a one-time payment of $865,332.16 to the
Division for the initial five-year life of the permit at issuance of the final permit. Novozymes
will make a similar one-time payment of $865,332.16 at each subsequent five-year renewal
of the permit, barring changes in circumstances. Novozymes requests that the offset pay-
ment be used to fund nutrient reduction and control projects in the Tar -Pamlico River Basin
and the Upper Tar River Subbasin. Please provide specific payee information to facilitate
the offset payment.
5. Tar -Pamlico Basin Association
As the Division is aware, Novozymes has petitioned for consideration for membership in the
Tar -Pamlico Basin Association (the "Association"). In the event that Novozymes becomes a
member of the Association after issuance of the final permit, and pending agreement of the
Association, the Division, and Novozymes for assignment of available reserve nutrient allo-
cations, Novozymes may request modification of this permit and the Association may request
modification of its overall permit to include Novozymes as a Co-Permittee and to revise As-
sociation nutrient allocations and limits accordingly.
Thank you again for your time and efforts regarding review and processing of the Draft Per-
mit. Please let me know if you have questions about any of the comments above.
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novozymes•*
Sinc rel ,
A gela J. Walsh
Novozymes North America, Inc.
cc: Julie Grzyb, Complex Permitting Unit
Mike Templeton, Complex Permitting Unit
Bing Bai, Complex Permitting Unit
Drew Hargrove, Assistant DEQ General Counsel
Steve Tedder, Tedderfarm Consulting
Katie Jones, Dewberry
Mike Poulios, Dewberry
(all via e-mail only)
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