NC0089621_Fact Sheet_20190620

Fact Sheet
NPDES Permit No. NCOO89621
Permit Writer: Bing Bai
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Date: June 20, 2019
Permitting Action:
❑ Renewal
❑ Renewal with Expansion
® New Discharge
❑ Modification
Briefly describe the proposed permitting action: Novozymes North America (NZNA or Novozymes) is
requesting a permit for a new 2 MGD discharge to Cedar Creek approximately 2.47 km (1.53 mi)
downstream from the Franklin County WWTP discharge. The facility currently has a pretreatment permit
to discharge 0.525 MGD to the Franklin County WWTP. In addition, the facility has a non -discharge
permit WQ0002806 for land application. NZNA wishes to expand production capabilities therefore they
need expanded wastewater treatment capacity. Novozymes is pursuing an NPDES permit since Franklin
County does not have the capacity to accept the proposed 2 MGD flow and the land application system
cannot handle an additional wastewater application volume.
The Novozymes facility produces industrial enzymes using a process called submerged fermentation.
This process involves growing carefully selected microorganisms (bacteria and fungi) in closed vessels
containing a rich broth of nutrients. As the microorganisms break down the nutrients to produce the
desired enzymes. The fermentation process requires nutrients based on renewable broth materials like
corn starch, sugar and soy grits. The first step in harvesting enzymes from the fermentation medium is to
remove insoluble product by centrifugation or microfltration. The biomass is recycled as a fertilizer and
the enzymes are concentrated by evaporation, membrane filtration or crystallization depending on their
intended application. Wastewaters generated in the facility consists of discharge from the fermentation
and recovery production processes and from site utilities such as cooling water and boiler blowdown.
Future wastewater flow characteristics are expected to be similar to existing wastewater flows. The
facility is required to remediate groundwater for nitrates therefore groundwater remediation treatment
wastewaters will also be discharged to the WWTP. The proposed treatment system consists of enhanced
nutrient removal, tertiary filters and RO.
Dewberry Engineers on behalf of Novozymes submitted a permit application for a 2 MGD discharge to
the Tar River on June 1, 2016. The application included an Engineering Alternative Analysis and a
Qual2K model report for the Tar River. In August 2016, the Division requested additional information on
the wastewater characterization, toxicity testing, and a Best Available Technology Study (BAT) per the
Tar -Pam surface water quality regulations. In December 2016, additional information regarding the BAT
analysis was requested. Novozymes submitted additional information and amendments to the permit
application on October 2016, February 2017, December 2017. These original application documents were
reviewed by Division of Water Resources, US Fish and Wildlife Services, and North Carolina Wildlife
Resources Commission. Due to the extremely high effluent potassium concentration (-600 mg/L) and the
habitat of endangered aquatic species immediately downstream of the proposed discharge in the Tar
River, multiple meetings/discussions were conducted between Novozymes, state/federal agencies and
environmental organizations. As a result, Novozymes agreed to relocate the discharge location from Tar
River to Cedar Creek, and install Reverse Osmosis (RO) to address the high potassium concentration in
Page 1 of 10

the effluent. On November 30, 2018, Novozymes submitted a revised permit application package: EPA
Form 1 and Form 2D, an Engineering Alternative Analysis (EAA), a Best Available Technology Study
for TN and TP, a Potassium aquatic life values Study Report (Ramboll report), and a revised QUAL2K
Model for discharge to Cedar Creek. Cedar Creek is a class C-NSW water in the Tar Pamlico River Basin
which entails nutrient controls. A portion of Cedar Creek approximately 4.5 miles downstream from the
discharge is a habitat for the endangered species.
The revised EAA and BAT analysis were reviewed and approved by the Division on February 8, 2019.
The Division agrees with proposed BAT limits for Total Nitrogen at 8.8 mg/L monthly average after
advanced nutrient removal and RO treatment (including assumed 1.0 mg/L of TN removal credit provided
by RO). If Novozymes decides to apply alternative treatment process other than RO to reduce potassium
concentration, the 8.8 mg/L BAT limit for TN will be maintained at the effluent side and Novozymes is
required to comply with it. The approved BAT limits for Total Phosphorus is 1.0 mg/L monthly average
at the effluent. The revised QUAL2K DO model was approved by the Division on February 6, 2019. The
revised Potassium aquatic life values study report was approved by the Division on December 20, 2018,
and the approved potassium aquatic life values are 17.14 mg/L acute and 16.5 mg/L chronic. These values
will be used for calculation of potassium limits.
Since Novozymes is not a member of the Tar -Pamlico Basin Association, in accordance with 15A NCAC
02B .0229(c), Novozymes is required to make a nutrient offset payment prior to permit issuance and at
each renewal. This permit is issued upon the receipt of Permittee's nutrient offset payment by the
Division in accordance with 15A NCAC 02B .0229. Should the permittee pursue membership in the Tar -
Pamlico basin Association during this permit term and TN and TP allocations are acquired, if the
allocations are less than required in this permit or the discharge loading to the Tar -Pamlico basin, the
Permittee may have to make an additional offset payment upon permit renewal. Novozymes is required
to notify both Raleigh Regional Office and the NPDES Complex Permitting Unit before the startup of the
wastewater treatment plant. In addition, Novozymes is required to complete and submit a complete EPA
Form 2C for the effluent no later than 180 days after the commencement of the discharge.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Novozymes North America, Inc./Franklinton Facility
Applicant Address:
P.O. Box 756, Franklinton, NC 27525
Facility Address:
77 Perrys Chapel Church Rd, Franklinton, NC 27525
Permitted Flow:
2.0 MGD
Facility Type/Waste:
Major industrial
Facility Class:
Class 4
Treatment Units:
Clarification, Advanced Nutrient Removal, Tertiary Filtration, Reverse
Osmosis, Evaporation
Pretreatment Program (Y/N)
N/A
County:
Franklin
Region
Raleigh
Page 2 of 10

2. Receiving Waterbody Information:
Receiving Waterbody Information
Receiving Stream(s):
Cedar Creek
Stream Classification:
C-NSW
Drainage Area (mi2):
33.6
Summer 7Q10 (cfs)
2.4
Winter 7Q 10 (cfs):
13
30Q2 (cfs):
10.8
Average Flow (cfs):
34.6
IWC (% effluent):
56.4%
303(d) listed/parameter:
No
Subject to TMDL/parameter:
Yes- TN/TP & Mercury
Subbasin/HUC/Segment index:
03-03-01 / 03020101 /28-29(2)
USGS Topo Quad:
C25SW/ Franklinton
3. Water Quality -Based Effluent Limitations (WQBELs)
a) Oxygen -Consuming Waste Limitations
BOD/Ammonia
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Limitations for ammonia
are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0 mg/1 (summer) and
1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria, utilizing a multiplication factor
of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Dewberry developed a calibrated Qual2K water quality model to evaluate BOD, ammonia and dissolved
oxygen. Qual2K is a model that represents one dimensional, steady state hydraulics used for modeling
water quality and dissolved oxygen profiles. The segment of Cedar Creek modeled for this study begins
at DWR ambient monitoring station 01600000 and ends 20.96 km downstream at the confluence with the
Tar River. The model includes the discharge from the Franklin County WWTP. The model was calibrated
with field measurements obtained during a sampling event in April 30 - May 2, 2018.
Several scenarios were modeled to represent the stream under average and critical conditions. The most
critical scenario was modeled under maximum permitted flow from Franklin County POTW (3 MGD)
and proposed NZNA discharge (2 MGD) at summertime conditions, saturated DO levels, and the
minimum 5 mg/l of effluent DO from both facilities. Under the most critical scenario, the model indicates
a minimum instream DO concentration of 5.43 mg/L, and a DO concentration at the proposed NZNA
discharge location of 5.74 mg/L. Further modeling of other conditions, including more conservative high
point source nutrient loads and 10th percentile in -stream DO concentrations, resulted in slight decreases
in the minimum DO, only reducing DO concentrations to 5.68 mg/l at the proposed NZNA discharge
location. Based on the totality of this model analysis, it appears that the proposed NZNA discharge
would not have significant impact on instream DO, and stream DO will be maintained above the 5 mg/L
standard with limits of 5 mg/L BOD and 1 mg/L ammonia nitrogen.
Page 3 of 10

c) Total Residual Chlorine
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
The facility does not treat domestic wastewater in the treatment system and the treatment process does not
include chlorination. No TRC limit will be implemented.
d) Reasonable Potential Analysis (RPA) for Toxicants
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
The permit is for a proposed discharge but data is available from the existing treatment system. Although
a new treatment system will be installed the wastewaters undergoing treatment will be very similar to
existing wastewaters. A reasonable potential analysis was conducted on effluent toxicant data collected
for the lUP between January 2015 and October 2016, and two RO pilot studies. Most of the analyses
were done with detection levels that are higher than the targeted Practical Quantitation Limit or
sufficiently sensitive test methods. Based on this analysis, the following permitting actions are proposed
for this permit:
Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: Cadmium, Copper, Potassium, Selenium, Lead
Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but
the maximum detection level was higher than the allowable: Silver
No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria
and the maximum predicted concentration was <50% of the allowable concentration: Arsenic,
Chlorides, Chromium, Molybdenum, Cyanide, Nickel, Zinc.
e) Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
The proposed permit requires a chronic WET limit at 56.4% effluent on a quarterly frequency.
Page 4 of 10

f) Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (811 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/l.
Mercury data will be obtained once the facility starts operation and completed EPA Form 2C is received.
g) Other TMDL/Nutrient Management Strategy Considerations
Cedar Creek is classified as C NSW. Regulations in 15A NCAC 2B .0229 require new industrial
discharges greater than 0.5 MGD who are not members of the Tar -Pamlico Basin Association to offset all
nutrient loads. The rule specifies that limits for TN and TP for industrial facilities are established based on
a Best Available Technology (BAT) determination. The purchase of offset credits is covered under G.S.
143-214.26. For a party other than government entity credits are purchased from a nutrient offset bank, or
if no credits are available through the bank, pay a nutrient offset fee into Riparian Buffer Restoration
Fund.
Novozymes developed a BAT study to determine the treatment technology that can economically achieve
the best treatment for total nitrogen and total phosphorus. The existing characteristics of the wastewaters
were used as the basis for the future wastewater characterization. To support the determination a
treatability study was completed in June 2017. Novozymes considered the following treatment
technologies: sequencing continuous flow, multiple stage continuous flow and sequencing batch reactors.
The selected technology is advanced nutrient removal utilizing conventional aeration. The technically
achievable effluent TN concentration for the selected technology is determined to be 8.8 mg/l, which
includes a nitrogen removal credit of 1.0 mg/l from the RO treatment process.
For total phosphorus a limit of 1 mg/1 is proposed. Chemical precipitation is the technology chosen to
meet the phosphorus limit. Individual TN/TP effluent limits are calculated based on 8.8 mg/1 TN and 1
mg/l TP and shown in table below. These TN/TP load limits were added to this permit to comply with the
nutrient permitting strategy for the Tar Pamlico Basin.
Table 3. TN/TP Load limits based on BAT limits
Flow
TN Load (lb/yr)
TP Load (lb/yr)
2.0 MGD
53,576
6,088
h) Other WOBEL Considerations
Cedar Creek is listed as a habitat for the endangered species dwarf wedgemussel. The proposed discharge
is high in salts such as potassium and chlorides. Studies have shown that freshwater mussels species are
sensitive to ammonia, sulfate, metals, chloride, sodium and potassium. North Carolina does not have a
water quality standard for potassium, nor the EPA has federal criteria. North Carolina rules have a
narrative standard for toxic substances to protect aquatic life. Ramboll submitted a potassium aquatic life
Page 5 of 10

values study report (Ramboll report) on behalf of Novozymes to evaluate the acute and chronic value for
instream potassium value in Cedar Creek. In the Ramboll report, the potassium -hardness relationship was
derived from various literatures and acute testing results. This relationship was used for calculating the
final in -stream warm low hardness surface water of North Carolina aquatic life values. Based on the
default instream hardness value of 25 mg/L, the proposed final aquatic life values for instream potassium
are 17.14 mg/L acute and 16.5 mg/L chronic. These values were reviewed by the Division's Water
Quality Standard Unit and US Fish and Wildlife Service (USFWS). USFWS recommended to use sand
substrate testing method instead of water based test for potassium toxicity to mussels. Since the sand
substrate test is not a standardized method with various uncertainties, the Division agrees with the water
based test proposed in the Ramboll report. Another concern from USFWS was that using a 28-day
maximum allowable toxicant concentrations (MATC) without any adjustment for longer -term exposures
is problematic, citing the 1973 Imlay study. However, due to lack of repeated studies for longer -term
exposures and related literature, the testing method provided in the Ramboll report is determined to
comprehensive and sufficient. The Division approved the proposed final aquatic life values for instream
potassium in the Ramboll report, and will use these values to calculate limits in the permit.
3. Technology -Based Effluent Limitations (TBELs)
The industrial process for Novozymes is classified under the OCPSF industrial category but the
fermentation process is not covered under the Federal Effluent Guidelines for OCPSF.
4. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2).
This proposed discharge is not subject to review for SEPA/FONSI determination.
An Engineer Alternative analysis was submitted with the permit application. Novozymes operates a
wastewater treatment system and disposes of the wastewater by spray irrigation under a non -discharge
permit (WQ0002806) and to the Franklin County POTW under an Industrial User Permit (lUP 0112). The
pre-treatment permit limits the facility to 525,000 gpd. The facility is currently under a Corrective Action
Plan which requires them to reduce the land application rate from 30 inches/yr to 8.5 inches/yr and
recover and treat 90,000 gpd. In addition, Novozymes desires to expand production at the site, requiring
additional capacity for wastewater treatment.
The existing wastewater treatment system has a capacity of 1.5 MGD. The proposed system will have a
maximum capacity of 2 MGD. The proposed treatment system will consist of primary clarifiers, advance
nutrient removal, storage lagoon, secondary clarifiers, phosphorus removal, dissolved air flotation,
tertiary filtration, reverse osmosis, evaporator, effluent discharge pump station and discharge pipeline.
The storage lagoon provides 26 days of storage.
All alternatives evaluated maintain the current permitted options of discharge to the Franklin County
POTW and the non -discharge land application system. The following alternatives were evaluated for the
expanded flows:
Page 6 of 10

1. Connection to an existing treatment system — Franklin County currently receives 525,000 gpd from
the facility under the Industrial User Permit. The Franklin County WWTP is permitted to treat and
discharge 3 MGD under its NPDES permit (NC0069311). Per the Franklin County WWTP
Headworks Analysis (HWA) dated 9/26/2018, the Franklin County WWTP has 0.82 MGD in flow
maximum allowable industrial load (MAIL) remaining. If Novozymes were to be permitted to
discharge 2.0 MGD to the Franklin County WWTP, this will require an expansion of existing
Franklin County WWTP, and an additional $24 to $50 million capital costs and $500,000 annual
operation costs, which will impose an unnecessary cost burden to existing residential and
commercial users. The estimated total 30-year cost for this alternative is $310 million. This will also
result in over allocation of ammonia, cadmium, cyanide, lead, and zinc on the HWA and upgrades of
NAZA's existing treatment plant. Therefore, connection to a Franklin County WWTP for expanded
flow is not considered feasible. Similarly, connection to the Louisburg POTW (with permitted flow
of 1.37 MGD) was also evaluated and considered not feasible.
2. Land Application — Novozymes is required to reduce the irrigation rate to the existing spray field
under a Corrective Action Plan in 2017 due to the high potassium concentration of its wastewater.
Novozymes evaluated buying additional land for spray irrigation but due to costs and the high levels
of salts contained in their wastewater, expansion of existing land application as a sole alternative for
additional flow is not considered feasible.
3. Onsite Reuse — Currently recovered groundwater is reused as non -contact cooling tower makeup
water. Novozymes is projected to supply the cooling towers with 100% reuse groundwater within the
next 3 years. However, Novozymes' Orthodox Union certifying body does not allow reuse water
elsewhere within the production process. As such, onsite reuse of proposed flow is not deemed
feasible.
4. Direct Discharge — Novozymes proposes to discharge treated wastewater to Cedar Creek as an
alternative for proposed expanded flow. This alterative requires the operation of reverse osmosis to
address high salt concentrations in their wastewater. With an estimated 30-year total cost of $266
million, this alternative provided justification that a direct discharge is the most environmentally
sound alternative from all reasonable cost-effective options [per 15A NCAC 2H .0105(c)(2)].
5. Anti -Backsliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits.
This is a proposed permit for new discharge, anti -backsliding is not applicable.
6. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ).
7. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
Page 7 of 10

(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
8. Summary of Proposed Permitting Actions:
Table 4. Proposed Permit Actions
Parameter
Proposed Action
Basis for Condition
Flow
MA 2 MGD
Design capacity for the treatment system, 15A NCAC 2B
.0505
Total Monthly Flow
Monitor and Report
G.S. 143-215.1(b). Used to calculate TN and TP Load.
BOD5
MA 5 mg/l
DM 7.5 mg/l
WQBEL. Based on the results of a Qual2K model for
protection of DO standard. 15A NCAC 2B.0200
NH3-N
MA 1 mg/l
DM 5 mg/l
WQBEL. Based on the results of a Qual2K model for
protection of DO standard. 15A NCAC 2B.0200
TSS
MA 10 mg/1
DM 15 mg/1
BPJ, Permittee agreed on more stringent limit than Secondary
Treatment Standard.
DO
> 5 mg/l
WQBEL. State WQ standard, 15A NCAC 2B .0200
pH
6-9 SU
WQBEL. State WQ standard, 15A NCAC 2B .0200
Temperature
Monitor Daily
WQBEL. State WQ standard, 15A NCAC 2B .0500
Conductivity
Monitor Daily
WQBEL. State WQ standard, 15A NCAC 2B .0500
Total Cadmium
MA 1.2 µg/L
DM 5.9 µg/L
Reasonable Potential Analysis, RP exists with max predicted
concentration > allowable concentration.
Total Copper
MA 15.6 µg/L
DM 19.3 µg/L
Reasonable Potential Analysis, RP exists with max predicted
concentration > allowable concentration.
Total Lead
MA 6 µg/L
DM 142.2 µg/L
Reasonable Potential Analysis, RP exists with max predicted
concentration > allowable concentration.
Total Potassium
MA 28.3 mg/L
DM 28.3 mg/L
Parameter of concern.
Total Selenium
MA 8.9 µg/L
DM 92.3 µg/L
Reasonable Potential Analysis, RP exists with max predicted
concentration > allowable concentration.
Total Silver
Monitor quarterly
Reasonable Potential Analysis, no RP with max predicted
concentration > 50% of allowable concentration.
TKN
Monitor monthly
WQBEL. State WQ standard, 15A NCAC 2B .0500
NO2-N + NO3-N
Monitor monthly
WQBEL. State WQ standard, 15A NCAC 2B .0500
TN
MA 8.8 mg/L
TBEL. BAT Limits
TN Load
Monitor monthly
53,576 lb/yr
WQBEL. Required individual TN/TP nutrient limits per 2015
Tar -Pamlico permitting strategy, and to comply with NC chl-a
WQS. 15A NCAC 2B.0200.
TP
MA 1 mg/L
TBEL. BAT Limits
TP Load
Monitor monthly
6,088 lb/yr
WQBEL. Required individual TN/TP nutrient limits per 2015
Tar -Pamlico permitting strategy, and to comply with NC chl-a
WQS. 15A NCAC 2B.0200.
Page 8 of 10

Hardness — Total as
CaCO2
Monitor quarterly
Required to assess dissolved metal limitations
Toxicity Test
Chronic limit, 56.4%
effluent
WQBEL. No toxics in toxic amounts. 15A NCAC 2B.0200
Instream DO
Add monitoring
15A NCAC 2B.0500
Instream pH
Add monitoring
15A NCAC 213.0500
Instream Temperature
Add monitoring
15A NCAC 213.0500
Instream Conductivity
Add monitoring
15A NCAC 213.0500
Instream Potassium
Add monitoring
15A NCAC 213.0500
Upstream Hardness
Add monitoring
Required to assess dissolved metal limitations
MGD — Million gallons per day, MA — Monthly Average, WA — Weekly Average, DM — Daily Max
9. Public Notice Schedule:
Permit to Public Notice: 04/11/2019
The Division will receive comments for a period of 30 days following the publication date of the public
notice. Any request for a public hearing shall be submitted to the Director within the 30 days comment
period indicating the interest of the party filing such request and the reasons why a hearing is warranted.
10. Fact Sheet Addendum (if applicable):
Comments on draft permit were received by the Division from Novozymes (Permittee) on May 6, 2019.
The Permittee requested reduction of monitoring frequency for effluent pollutants and instream
monitoring requirements. As a Grade IV facility with SIC code 2869, monitoring frequency and instream
monitoring requirements are determined in accordance with 15A NCAC 02B .0508. Therefore,
monitoring frequency remains the same as in the draft permit. The detailed comments from the Permittee
and the Division's response are provided in the Fact Sheet Attachments.
Tar Pamlico Basin Association (TPBA) provided one comment on the nutrient offset payment on May 6,
2019. Since this comment does not affect the NPDES permit, it will not be included in the factsheet and
will be addressed separately.
Sound Rivers (Pamlico -Tar Riverkeeper) and SELC submitted comments on May 13, 2019 regarding
nutrient allocation and groundwater contamination, endangered species and mussel toxicity, instream
monitoring requirement and the handling of RO concentrates. The detailed comments and Division's
responses are provided in the Fact Sheet Attachments.
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If Yes, list changes and their basis below:
Footnote 3 in Section A. (2) Instream Monitoring Requirements was revised per the comments
from the Permittee and Tar Pamlico Basin Association. If the Permittee becomes a member of the
TPBA, instream monitoring may be waived only if the Association agrees to sample all required
parameter at locations specified in the permit. The Permittee is responsible for submitting all
instream sampling results with permit renewal application.
Special condition A. (7) Relocation of Outfall 001 was added to the permit based on the
comments provided by the Permittee and SELC that the existing Outfall 001 discharges to
Page 9 of 10

wetland area. Novozymes shall apply for relocation of Outfa11001 to downstream of the wetland
area within 12 months of permit issuance.
11. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• Dissolved Metals Implementation/Freshwater or Saltwater
• NH3-N and TRC WLA
• Division's responses to all pertinent comments
Page 10 of 10

Permit No. NCO089621
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as
approved.
Table 1. NC Dissolved Metals Water Q ality Standards/A uatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/l
(Dissolved)
Acute SW, µg/l
(Dissolved)
Chronic SW, µg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
213.0200 (e.g., arsenic at 10 µg/l for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.136672-[ln hardness] (0.041838)} e^ f0.9151 [ln hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness] (0.041838)} e^ f0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.101672-[ln hardness] (0.041838)} e^ f0.7998[ln hardness]-4.44511
Chromium III, Acute
WER*0.316 e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 e^{0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 eAtO.8545[ln hardness]-1.7021
Lead, Acute
WER*{1.46203-[ln hardness](0.145712)) • e^{1.273[ln hardness]-1.460)
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)) • e^{1.273[ln hardness]-4.705)
Nickel, Acute
WER*0.998 eAtO.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 eAtO.8460[ln hardness]+0.0584}
Page 1 of 4

Permit No. NCO089621
Silver, Acute
WER*0.85 • e^{l.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 e^{0.8473[ln hardness]+0.884}
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below
detection level), then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q 10 (the spreadsheet automatically calculates
the 1 Q 10 using the formula I Q 10 = 0.843 (s7Q 10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
Page 2 of 4

Permit No. NCO089621
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
_ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + (s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q 10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Cdiss = 1
Ctotal I + { [Kpo] [SS(i+a)] [10-6] }
Where:
ss = in -stream suspended solids concentration [mg/l], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q 10 + Qw) (Cwgs) — (s7Q 10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q 10)
s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q 10 may be incorporated as applicable:
IQ 10 = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0089621
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
25
Default with no data
[Total as CaCO31
Average Upstream Hardness (mg/L)
33
Ramboll report
[Total as CaCO31
7Q10 summer (cfs)
2.4
NPDES files, BIMS
1 Q 10 (cfs)
2.01
Calculated from 7Q 10 summer
Permitted Flow (MGD)
2
NPDES files, BIMS
Date: 2/26/2019
Permit Writer: Bing Bai
Page 4 of 4

NH3/TRC WLA Calculations
Facility: Novozymes WWTP
PermitNo. NC0089621
Prepared By: Bing Bai
Enter Design Flow (MGD): 2
Enter s7Q10 (cfs): 2.4
Enter w7Q10 cfs : 13
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
2.4
s7Q10 (CFS)
2.4
DESIGN FLOW (MGD)
2
DESIGN FLOW (MGD)
2
DESIGN FLOW (CFS)
3.1
DESIGN FLOW (CFS)
3.1
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1)
0
Upstream Bkgd (mg/1)
0.22
IWC (%)
56.36
IWC (%)
56.36
Allowable Conc. (ug/1)
30
Allowable Conc. (mg/1)
1.6
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
13
Monthly Average Limit:
200/100ml DESIGN FLOW (MGD)
2
(If DF >331; Monitor)
DESIGN FLOW (CFS)
3.1
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF)
1.77 Upstream Bkgd (mg/1)
0.22
IWC (%)
19.25
Allowable Conc. (mg/1)
8.4
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
Facility Name
WWTP/WTP Class
NPDES Permit
Outfal I
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
❑CHECK IF HQW OR ORW WQS
Novozymes WWTP
Class IV
NCO089621
001
2.000
Cedar Creek
03020101
C, NSW
❑Apply WS Hardness WQC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
2.40
13.00
10.80
34.60
2.01
Effluent Hardness
--------------------------------
Upstream Hardness
.------------
Combined Hardness Chronic
.-----------_
Combined Hardness Acute
25 mg/L (Avg)
33 mg/L (Avg)
---------- -----
28.49 m /L
I9 ----------
28.15 /L
Data Source(s)
❑CHECK TO APPLY MODEL
Par01
Par02
Par03
Par04
Par05
Par06E
Par07
ParOB
ParO9
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Part B
Par19
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name WQS Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
0.6512
FW
3.5930
ug/L
Chlorides
Aquatic Life
NC
230
FW
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
131.0352
FW
997.3715
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
Ng/L
Copper
Aquatic Life
NC
8.8119
FW
11.7096
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
3.4075
FW
86.2573
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
41.5846
FW
370.5737
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
0.3634
ug/L
Zinc
Aquatic Life
NC
141.5759
FW
138.9887
ug/L
Potassium
Aquatic Life
NC
16.5
FW
17.14
mg/L
2 MGD RPA Cedar Creek 1-7-2019, input
2/18/2019

2 MGD RPA Cedar Creek 1-7-2019, input
2/18/2019

Novozymes WWTP - Outfall 001
NCO089621 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 2 MGD
MAXIMUM
Qw (MGD) = 2.0000
1Q10S (cfs) = 2.01
7Q10S (cfs) = 2.40
7Q10W (cfs) = 13.00
30Q2 (cfs) = 10.80
Avg. Stream Flow, QA (cfs) = 34.60
Receiving Stream: Cedar Creek HUC 03020101
DATA POINTS = 58
WWTP/WTP Class: Class IV
IWC% @ 1Q10S = 60.66536204
IWC% @ 7Q10S = 56.36363636
IWC% @ 7Q10W = 19.25465839
IWC% @ 30Q2 = 22.30215827
IW%C @ QA = 8.222811671
Stream Class: C, NSW
COMBINED HARDNESS (mg/L)
Acute = 28.15 mg/L
Chronic = 28.49 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
J
a
D
Applied
Chronic Acute
n # Det. Max Pred Cw Allowable Cw
Standard
Acute (FW): 560.5
No RP, Predicted Max < 50% of Allowable Cw - No
Arsenic
c
150 FW(7Q10s) 340
ug/L
Monitoring required
7 0
34.2
---------------------------------------------
Chronic (FW) 266.1
No RP, Predicted Max < 50% of Allowable Cw - No
C.V. (default)
M_ax_MDL = 34
Monitoring required
Arsenic
C
10 HH/WS(Qavg)
ug/L
Note: n 5 9
NO DETECTS
Chronic (HH) 121.6
No RP, Predicted Max < 50%of Allowable Cw - No
Limited data set
Max MDL = 34
Monitoring required
Acute: 107.15
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
0 0
N/A
--Chronic:-----11.53 --
--------------------------
Acute: 5.923
Cadmium
NC
0.6512 FW(7Q10s) 3.5930
ug/L
9 0
3.258
Note: n 5 9
C.V. (default)
Chronic: 1.155
RP shown -apply Monthly Monitoring with Limit
Limited data set
NO DETECTS
Max MDL = 3.6
Acute: NO WQS
Chlorides
NC
230 FW(7Q10s)
mg/L
2 2
28.8
Note: n < 9
C.V. (default)
Chronic: 408.1
No RP, Predicted Max < 50% of Allowable Cw - No
Limited data set
No value > Allowable Cw
Monitoring required
Acute: 26.4
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
0 0
N/A
--Chronic:-----19-5 --
--------------------------
Chromium, Total
NC
µg/L
9 0
12.7
Max reported value = 7
a: No monitoring required if all Total Chromium
samples are < 5 pg/L or Pred. max for Total Cr is <
Note n < 9
C.V. default
(default)
allowable Cw for Cr VI.
Limited data set
NO DETECTS
Max MDL = 14
Acute: 19.30
Copper
NC
8.8119 FW(7Q10s) 11.7096
ug/L
22 13
26.20
Chronic: 15.63
RP shown - apply Monthly Monitoring with Limit
7 values > Allowable Cw
Acute: 36.3
All samples were < 4.9 ug/L
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
10 0
5.0
---------------------------------------------
Chronic: 8.9
No RP, Predicted Max < 50% of Allowable Cw - No
NO DETECTS
Max MDL = 10
Monitoring required
Acute: 142.185
Lead
NC
3.4075 FW(7Q10s) 86.2573
ug/L
6 0
6.634
Note: n < 9
C.V. (default)
Chronic: 6.046
RP shown -apply Monthly Monitoring with Limit
Limited data set
NO DETECTS
Max MDL = 6.2
2 MGD RPA Cedar Creek 1-7-2019, rpa
Page 1 of 2 2/18/2019

Novozymes WWTP - Outfall 001
NCO089621 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 2 MGD
Acute: NO WQS
Molybdenum
NC
2000 HH(7Q10s)
u,/L
9 0
22.6
Note: n < 9
C.V. (default)
Chronic: 3,548.4
No RP, Predicted Max < 50% of Allowable Cw - No
Limited data set
NO DETECTS
Max MDL = 25
Monitoring required
Acute (FW): 610.8
Nickel
NC
41.5846 FW(7Q10s) 370.5737
µg/L
9 0
19.9
_
Chronic (FW) 73.8
No RP, Predicted Max < 50% of Allowable Cw - No
Note: n 5 9
C.V. (default)
Max MDL = 22
Monitoring required
Nickel
NC
25.0000 WS(7Q10s)
µg/L
Limited data set
NO DETECTS
_ _
Chronic (WS) 44.4
Max MDL = 22
Acute: 92.3
Selenium
NC
5 FW(7Q10s) 56
ug/L
9 0
56.1
Note: n <_ 9
C.V. (default)
Chronic: 8.9
RP shown -apply Monthly Monitoring with Limit
Limited data set
NO DETECTS
Max MDL = 62
Acute: 0.599
No detects. Permittee shall report to targeted PQL
Silver
NC
0.06 FW(7Q10s) 0.3634
ug/L
21 0
2.741
___ _ ____ _ ___
Chronic: 0.106
-------- _________
No limit, apply quarterly monitoring
NO DETECTS
Max MDL = 2.7
Acute: 229.1
Zinc
NC
141.5759 FW(7Q10s) 138.9887
ug/L
23 0
44.3
Chronic: 251.2
No RP, Predicted Max < 50% of Allowable Cw - No
NO DETECTS
Max MDL = 72
Monitoring required
Acute: 28.25335
Pollutant of concern
Potassium
NC
16.5 FW(7Q10s) 17.14
mg/L
2 2
50.02800
Note: n < 9
C.V. (default)
Chronic: 29.27419
1
RP shown -apply Monthly Monitoring with Limit
Limited data set
No value > Allowable Cw
2 MGD RPA Cedar Creek 1-7-2019, rpa
Page 2 of 2 2/18/2019

REASONABLE POTENTIAL ANALYSIS
H1
Use "PASTE SPECIAL
H2
Use "PASTE SPECIAL
ParOl & Par02
Use "PASTE SPECIAL
Par04
Use "PASTE SPECIAL
Effluent Hardness
Values" then "COPY' .
Upstream
Hardness
Values" then --copy--.
Arsenic
Values" then "COPY' .
Cadmium
Values" then "COPY"
Maximum data points
Maximum data points
Maximum data points
Maximum data points
- 58
= 58
= 58
= 56
Date
Data BDL=1/2DL
Results
Date
Data
BDL=II2DL
Results
Date
Data
BDL=1/2DL
Results
Date
Data
BDL=II2DL
Results
1
25 25
Std Dev.
N/A
1
33
33
Std Dev.
N/A
1
< 27
13.5
Std Dev.
4.7145
1
< 1.8
0.9
Std Dev.
0.5209
2
Mean
25.0000
2
Mean
33.0000
2
< 34
17
Mean
13.6429
2
< 1.8
0.9
Mean
0.9778
3
C.V.
0.0000
3
C.V.
0.0000
3
< 34
17
C.V. (default)
0.6000
3
< 1.8
0.9
C.V. (default)
0.6000
4
n
1
4
In
1
4
< 34
17
n
7
4
< 1.8
0.9
In
9
5
10th Per value
25.00 mg/L
5
10th Per value
33.00 mg/L
5
< 34
17
5
< 1.8
0.9
6
Average Value
25.00 mg/L
6
Average Value
33.00 mg/L
6
< 14
7
Mult Factor =
2.01
6
< 0.7
0.35
Mult Factor =
1.81
7
Max. Value
25.00 mg/L
7
Max. Value
33.00 mg/L
7
< 14
7
Max. Value
17.0 ug/L
7
< 0.7
0.35
Max. Value
1.800 ug/L
8
8
8
Max. Pred Cw
34.2 ug/L
8
9/6/2018
< 3.6
1.8
Max. Pred Cw
3.258 ug/L
9
9
9
9
9/18/2018
< 3.6
1.8
Per05
Use "PASTE SPECIAL
Par10
Use "PASTE SPECIAL
Pall
Use "PASTE SPECULL
Parl2
Use "PASTE SPECIAL
Chlorides
Values" then"COPY'.
Chromium. Total
Val- men COPY
Cower
vamee"than copr'.
Cvanide
Values"then "COPY"
Maximum data points
Maximum data points
tlmum tlata points
Maximum data points
Date
Data BDL=1/2DL
Results
=58
Date
Data
BDL=112DL
Results
=ss
Date
Data
BDL=1/2DL
Results
=Sb
Date
Data
BDL=112DL
Results
=58
1
9/6/2018
3 3
Std Dev.
3.2527
1
< 7
3.5
Std Dev.
2.0140
1
20
20
Std Dev.
6.4113
1
< 5
5
Std Dev.
0.0000
2
9/18/2018
7.6 7.6
Mean
5.3
2
< 7
3.5
Mean
3.8111
2
10
10
Mean
11.2591
2
< 5
5
Mean
5.00
3
C.V. (default)
0.6000
3
< 7
3.5
C.V. (default)
0.6000
3
10
10
C.V.
0.5694
3
< 5
5
C.V.
0.0000
4
n
2
4
< 7
3.5
In
9
4
20
20
n
22
4
< 5
5
In
10
5
5
< 7
3.5
5
20
20
5
< 5
5
6
Mult Factor =
3.8
6
< 2.8
1.4
Mult Factor =
1.81
6
< 10
5
Mult Factor =
1.31
6
< 5
5
Mult Factor =
1.00
7
Max. Value
7.6 mg/L
7
< 2.8
1.4
Max. Value
7.0 pg/L
7
< 10
5
Max. Value
20.00 ug/L
7
< 5
5
Max. Value
5.0 ug/L
8
Max. Pred Cw
28.8 mg/L
8
9/6/2018
< 14
7
Max. Pred Cw
12.7 pg/L
8
20
20
Max. Pred Cw
26.20 ug/L
8
< 5
5
Max. Pred Cw
5.0 ug/L
9
9
9/18/2018
< 14
7
9
20
20
9
9/6/2018
< 5
5
10
10
10
< 10
5
10
9/18/2018
< 5
5
11
11
11
< 10
5
11
12
12
12
< 10
5
12
13
13
13
10
10
13
14
14
14
10
10
14
15
15
15
< 10
5
15
i6
16
i6
10
10
16
17
17
17
< 10
5
17
18
18
18
< 10
5
18
19
19
19
10
10
19
20
20
20
20
20
20
21
21
21
9/6/2018
19.7
19.7
21
22
22
22
9/18/2018
< 16
8
22
r'19
1
2
3
4
5
6
7
8
9
< 0.7
< 0.7
< 0.3
< 6.2
< 6.2
< 6.2
Lead
BDL=1/2DL
0.35
0.35
0.15
3.1
3.1
3.1
Results
Std Dev.
Mean
C.V. (default)
n
Mult Factor=
Max. Value
Max. Pred Cw
LUsePASTE SPEC
s" then"COPY"
data points
8Date
1.5445
1.6917
0.6000
6
2.14
3.100 ug/L
6.634 ug/L
rarto
1
2
3
4
5
6
7
8
9
9/6/2018
9/18/2018
Molvbdenum
Data BDL=II2DL
< 12.5 6.25
< 12.5 6.25
< 12.5 6.25
< 16.8 8.4
< 14 7
< 5 2.5
< 5 2.5
< 25 12.5
< 25 12.5
Results
Std Dev.
Mean
C.V. (default)
n
Mult Factor=
Max. Value
Max. Pred Cw
PECIAL
COPY".
points
He
.
12.5 ug/L
22.6 ug/L
ran t
1
2
3
4
5
6
7
8
9
h rar 8
Date Data
<
<
<
<
<
<
<
9/6/2018 <
9/18/2018 <
9
9
9
9
11
6
7
22
22
Nickel
BDL=1/2DL
4.5
4.5
4.5
4.5
5.5
3
3.5
11
11
Results
Std Dev.
Mean
C.V. (default)
n
Mult Factor
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL
Values" then"COPY".
Maximum data points
=58
3.0425
5.7778
0.6000
9
1.81
11.0 pg/L
19.9 pg/L
rar a
Date
1
2
3
4
5
6
7
8 9/6/2018
9 9/18/2018
Data
< 25
< 25
< 25
< 25
< 31
< 12
< 12
< 62
< 62
Selenium
BDL=II2DL
12.5
12.5
12.5
12.5
15.5
6
6
31
31
Results=56
Std Dev.
Mean
C.V. (default)
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL
Values"then"COPY"mum
Maximum data pointsDate
9.3341
15.5000
0.6000
9
1.81
31.0 ug/L
56.1 ug/L
29 Use "PASTE SPEC
Par21 se "PASTE SPECIAL
Par22 Use "PASTE SPECIAL
Silver
Values"then"COP
Zinc
Vawes"then "Copy.
Potassium
Values" then "COPY".
Maximum data poi
Maximum data points
Maximum data points
Date
Data
BDL=1/2DL
Results
=58
Date
Data
BDL=112DL
Results
=58
Date Data
BDL=1/2DL
Results
=58
1
< 0.1
0.05
Std Dev.
0.2840
1
< 34
17
Std Dev.
6.2370
1
9/6/2018
6.98
6.98
Std Dev.
4.3982
2
< 0.1
0.05
Mean
0.1286
2
< 38
19
Mean
13.8261
2
9/18/2018
13.2
13.2
Mean
10.0900
3
< 0.1
0.05
C.V.
2.2087
3
< 27
13.5
C.V.
0.4511
3
C.V. (default)
0.6000
4
< 0.2
0.1
n
21
4
< 31
15.5
In
23
4
n
2
5
< 0.1
0.05
5
< 24
12
5
6
< 0.1
0.05
Mult Factor =
2.03
6
< 19
9.5
Mult Factor =
1.23
6
Mult Factor =
3.79
7
< 0.1
0.05
Max. Value
1.350 ug/L
7
< 19
9.5
Max. Value
36.0 ug/L
7
Max. Value
13.200000 mg/L
8
< 0.1
0.05
Max. Pred Cw
2.741 ug/L
8
< 19
9.5
Max. Pred Cw
44.3 ug/L
8
Max. Pred Cw
50.028000 mg/L
9
< 0.1
0.05
9
< 19
9.5
9
0
< 2.7
1.35
10
< 19
9.5
10
1
< 0.3
0.15
11
< 19
9.5
11
2
< 0.1
0.05
12
< 19
9.5
12
3
< 0.1
0.05
13
< 20
10
13
4
< 0.1
0.05
14
< 32
16
14
5
< 0.1
0.05
15
< 25
12.5
15
6
< 0.1
0.05
16
< 22
11
16
7
< 0.1
0.05
17
< 22
11
17
8
< 0.1
0.05
18
< 22
11
18
9
< 0.1
0.05
19
< 72
36
19
'.0
< 0.5
0.25
20
< 22
11
20
'.1
< 0.1
0.05
21
< 24
12
21
22
9/6/2018
< 44
22
22
3 ME
23
9/18/2018
< 44
22
23

NCO089621 Factsheet Attachment A — Division's response to Novozymes' Comments
The Division received comments from Novozymes on May 6, 2019 and provides the following
responses:
1. Effluent Limitations and Monitoring Requirements — Part I, Section A. (1)
a. For consistency with other local NPDES permit conditions for Grade IV facilities, please revise
the measurement frequency or BOD, TSS, NH3, Dissolved Oxygen, pH, and Temperature from
daily to 3 times per week. Alternatively, we would request reporting of TSS, DO, pH and
Temperature using online instrumentation
DWR Response:
Monitoring frequency for BOD, TSS, NH3, Dissolved Oxygen, pH and Temperature is required in the
15A NCAC 02B .0508, and determined by the facility class and SIC code. For Grade IV facility with SIC
code 2869, daily monitoring frequency is required.
Novozymes shall follow the Guidelines Establishing Test Procedures for the Analysis of Pollutants as
stated in 40 CFR Part 136 for measuring and reporting of TSS, DO, pH and Temperature.
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.
DWR Response:
Effluent metal data collected from Novozymes' SIU permit and two runs of the RO pilot tests were
evaluated in the Reasonable Potential Analysis, a statistical tool used to determine whether a toxic
substance has reasonable potential to exceed surface water quality standards (WQS). According to the
RPA results and the Division's guidance on determinations of monitoring frequency for toxic substances
(memo dated July 15, 2010), toxic substances that show reasonable potential to exceed NC Water Quality
Standards will receive monthly monitoring and a permit limit, and toxic substances that do not show
reasonable potential but the predicted maximum concentration exceeds 50% of allowable discharge
concentration will receive quarterly monitoring without a limit. For your facility, reasonable potential to
violate NC Water Quality Standards was shown for Cadmium, Copper, Lead, and Selenium, so monthly
monitoring with a permit limit were required for these metals.
c. Novozymes requests that a CBOD limit be used rather than the BOD 5-day limit currently in
the Draft Permit.
DWR Response:
In accordance with 15A NCAC 02B .0200, all new facility discharging to Tar -Pamlico River Basin will
receive a monthly average limit of 5 mg/L for BOD5. Based on the wastewater characteristics, the 5 mg/L
BOD5 limit can be converted to CBOD5 limit by multiplying the CBOD/BOD correlation coefficient.
Novozymes will have to provide testing results and demonstrate the correlation between BOD and CBOD
for your wastewater to the Division, and then the BOD limit can be converted to CBOD limits.
2. Instream Monitoring Requirements — Part I, Section A. (2)
a. Please delete the instream monitoring requirement for potassium. Potassium will be controlled
by the reserve osmosis (RO) system to be installed by Novozymes, and potassium levels in the

NCO089621 Factsheet Attachment A — Division's response to Novozymes' Comments
effluent will be measured on a regular basis. This is more than adequate to address potassium
concerns.
DWR Response:
Since Novozymes is a new discharger, and potassium is the major pollutant of concern, the Division
believes it is adequate to include instream monitoring for potassium to evaluate the downstream impacts
from Novozymes' discharge for the first permit term. The necessity of instream potassium monitoring
will be reevaluated upon permit renewal.
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.
DWR Response:
hnstream monitoring requirement is determined in accordance with 15A NCAC 02B. 0500, and cannot be
deleted entirely from the permit. Since Novozymes is a new discharger, the Division believes it is
adequate to have instream sampling results at specified up and downstream locations for the first permit
term to evaluate instream impacts and confirm model predictions. Should Novozymes become a member
of the Tar -Pamlico Basin Association during this permit term, the instream monitoring requirements for
DO, pH, Temperature, and conductivity can be waived ONLY if a written agreement is received by the
Division that the Association agrees to perform instream sampling for DO, pH, Temperature, and
conductivity at the frequency and site locations specified in the permit. This will be addressed when
Novozymes becomes a member of the Association.
3. Electronic Reporting — Part I, Section A. (7)
Beginning on December 21, 2020, the Draft Permit requires electronic reporting of
"Pretreatment Program Annual Reports" and "Clean Water Act Section 316(b) Annual
Reports." It appears these requirements were included in the Draft Permit in error.
DWR Response:
This is a standard NPDES condition for electronic reporting. Any non -applicable parts in the condition
will not apply to your facility.
4. Nutrient Offset Payment
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 payment 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.
DWR Response:
Receipt of the payment will be acknowledged in the cover letter with the final permit. In accordance with
the Tar -Pam NSW Rules nitrogen and phosphorus loads shall be offset at the rate of 110 percent of the
cost to implement BMP's designed to reduce that same loading by the new discharge above 0.05 MGD.

NCO089621 Factsheet Attachment A — Division's response to Novozymes' Comments
5. Tar -Pamlico Basin 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 allocations, 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 Association nutrient allocations and limits accordingly.
DWR Response:
The Division acknowledges that Novozymes and the Association may request modifications to related
permits.
Responses to additional comments on draft permit submitted by Novozymes on April 1, 2019
1. The permit is expected to be for a five-year term. Accordingly, the expiration date should be
five years from the date of issuance.
DWR Response:
A five-year permit term will be issued to this permit, and the permit expiration date will be determined
based on the effective date of the final permit.
3.c. The Measurement Frequency effluent potassium should be modified to be consistent with the
Measurement Frequency of other metals; this should be measured on a quarterly basis.
DWR Response:
Monitoring frequency for effluent potassium is determined in accordance with 2016 NPDES Permitting
Guidance for Implementation of Instream Dissolved Metal Standards and Reasonable Potential Analysis.
As a pollutant of concern, limits for potassium are included in the permit, and all limited toxic substances
will receive a monthly monitoring requirements. Please refer to the attached Memorandum for better
understanding of how limits and monitoring frequency are determined.
4.a. The Measurement Frequency of instream potassium should be modified to be consistent with
the Measurement Frequency of other metals; this should be measured on a quarterly basis.
DWR Response:
Monthly instream sampling for potassium is added in the permit to be in consistent with monthly effluent
potassium monitoring.

NC0089621 Factsheet Attachment B — Division's responses to Sound Rivers and SELC comments
The Division received comments from Sound Rivers and SELC on May 13, 2019 and provides
the following responses:
Comment #1: Nutrient Allocation and Groundwater Contamination:
DWR Response:
The nitrogen issues at Raleigh and Novozymes are similar in that both land -applied residuals and/or
wastewaters resulted in exceedances of groundwater standards for NO3-N. The circumstances in each
case are unique in other respects, so their resolution may be unique as well.
Under the 2L rules in place at the time, Raleigh was ineligible to use natural attenuation to remediate
groundwater at its site, so it requested a variance from the rules that prohibited the use of natural
attenuation at permitted facilities. Provisions for modeling the site and counting the estimated
groundwater nitrogen flux as a part of the City's discharge of TN under its NPDES permit made the
request acceptable.
The Division has conditionally approved Novozymes' corrective action plan, but that approval is
conditional, pending Novozymes' being able to demonstrate that the groundwater discharging into
surface water at the site does not cause a standard violation.
Comment #2: Cedar Creek Discharge:
DWR Response:
Novozymes has agreed to relocate their Outfall 001 to create more distance between the point of
discharge and the wetlands. A special condition has been added to the permit requiring the Permittee
to relocate the proposed outfall downstream of the wetlands area within 12 months of permit
issuance.
Comment #3: Endangered Species and Mussel Toxicity:
USFWS item #1— The 6.9 mg/L MATC from Wang et al. (2018) is a more appropriate starting
point than the values used in the Ramboll Report
DWR Response:
Standardized laboratory methods are used for the development and assessment of water quality
standards as they have undergone refinement and validation to minimize uncertainty and produce
accurate, consistent, and reproduceable results. The standardized method for aquatic toxicity testing
using freshwater mussels is the ASTM International Standard Guide for Conducting Laboratory
Toxicity Tests with Freshwater Mussels (ASTM E2455-06). The Wang et al. (2018) paper cited by
USFWS provides maximum allowable toxicity concentrations (MATCs) for potassium equal to 32
mg/L for a 28-day water -only test using the ASTM method and 6.9 mg/L using a modified version of
the method which adds a sand substrate to the test chambers. Sand was added to the test chambers as
part of an investigation into reducing the degree of biofouling that may occur during the 28-day
water -only tests. Since the practice of adding a sand substrate was an experimental modification of
the standardized ASTM method, it is inappropriate to use this data to establish or implement water
quality standards. DWR recommends that the data derived using the unmodified water -only ASTM
method be used as it provides more confidence in the test results.

NCO089621 Factsheet Attachment B — Division's responses to Sound Rivers and SELC comments
USFWS item #2 — The hardness adjustment should reflect receiving water conditions
DWR Response:
The North Carolina surface water quality standards in rule 15A NCAC 02B .0211 recognize
"hardness -dependent" metals. As an alkali metal, the toxicity of potassium to freshwater organisms is
demonstrated to be dependent on water hardness. Ramboll characterized the relationship between
potassium toxicity and water hardness using a hardness of 25 mg/L, as well as the 10' percentile (24
mg/L) of the hardness of the receiving stream as summarized in the USFWS draft letter to DWR
NPDES permitting staff dated March 17, 2017.
USFWS item #3 — Using a 28-day MATC without any adjustment for longer -term exposures is
problematic
DWR Response:
The standardized ASTM method evaluates chronic toxicity using a 28-day exposure period. The
study conducted by Imlay (1973) and cited by USFWS employed a 300-day exposure period. The
Imlay study is a unique study that DWR has not seen replicated. While the study provides important
information regarding the long-term effects of pollutants on freshwater mussels, it would be
inappropriate to implement the results of this study due to its use of a unique and unverified method.
The application of a safety factor to a MATC, which is synonymous to a chronic value, would
conflict with regulations for determining chronic toxicity to aquatic life established in 15A NCAC
02B .0208 (1).
Comment #4: Monitoring:
DWR Response:
The Division has conducted several macroinvertebrate assessments on Cedar Creek from
1990 to 2017, including multiple observations at two upstream stations and one downstream
station from Novozymes' proposed discharge location. No localized impairment was
observed during these assessments. Furthermore, the Division has additional assessments
planned on Cedar Creek for 2020, and the results will be compared to previous assessments
and used to determine whether additional macroinvertebrates assessments are needed in the
permit.
Comment #5: Reverse Osmosis Treatment:
DWR Response:
Concentrate wastewaters from the Reverse Osmosis (RO) system and wastewaters resulting from
cleaning the RO membranes are not covered under this permit and shall not be discharged. The
facility is investigating other means of concentrate disposal.