NCS000061_Staff Report_20190716

NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000061
Lenoir Mirror Company
Lenoir, NC
Facility Activities and Processes:
• SIC Code: 3231— Purchased Glass Products. Facility is approximately 22 acres with approximately 60%
impervious cover. The site has one outfall that discharges to Gunpowder Creek, a class C stream in the
Catawba River Basin.
• Lenoir Mirror Company is a mirror manufacturing and glass fabricating company. LMC's manufacturing
process consists of mirror plating and cutting, grinding, and polishing of both clear and mirrored glass.
Clear glass manufacturing operations generate grinding and polishing wastewater that is treated onsite,
and clear glass waste cullet that is recycled by the stock glass suppliers. Mirror manufacturing operations
generate grinding and polishing wastewater, process coating wastewater, paint process line cleaning
waste (solvent recovery still bottom sludge), and mirror waste cullet. The waste mirror cullet is picked up
by recyclers and/or permitted to the Caldwell County, NC landfill as a special non -hazardous waste subject
to the RCRA, TCLP testing, annually. The waste paint still bottoms are permitted under a "Small Quantity
Generator" permit. The waste paint is picked up by common carrier and sent to Giant Resource Recover,
Sumter, SC.
• The mirror production process includes cleaning, rinsing, coating, drying, and polishing of the stock glass.
Clear glass stock is manually loaded onto the mirror coating line. The clear glass is mechanically brazed
"wet deposition process" on one side to provide bonding surface for the mirror coating, cleaned, and
rinsed to protect the metal coating, a layer of paint is applied to the surface and cured in a bake oven. The
mirrored glass is then cut -to -size, polished, cleaned, fabricated and shipped to the customer. Mirror cullet
is produced when either breakage, rejects, or trimming glass occurs.
Monitoring Information:
• The facility has been monitoring for BOD, COD, TSS, Lead, Silver and for pH, oil/grease, and new motor oil
usage associated with onsite vehicle maintenance.
• Previous permit did have a tier system.
• There are missing paper files for multiple monitoring events between 2009 and 2018. One sampling event
occurred in April 2018, one in April 2016, one in November 2015, one in June 2014, one in December
2014, one in August 2009.
• In the March 2009 Staff report, it was reported the facility has a history of incomplete data:
1. "The previous permit required a minimum of 7 analytical sampling events of which 1 was
competed in 2006"
2. "Visual monitoring was required to be performed semi-annually, but only 5 inspections were
recorded for the current permit."
3. "Permittee says monitoring was performed, but cannot find documentation."
• There was an exceedance of BOD at 124mg/I (benchmark: 30 mg/1) recorded in 2018. It is unknown if a
Tier event began after the BOD exceedance in 2018.
• DEQ benchmark levels are below the MQL of Blue Ridge Labs for silver and lead from 2009-2018.
• Several issues have been highlighted in past inspections and are detailed in BIMS.
Surface Water Information:
• Gunpowder Creek is not listed as an impaired water.
• There are no TMDL's for Gunpowder Creek.
Discussions with the Facility:
• An email was sent, and a voicemail was left for Jack Debeve, the site/permit contact, on 4/25/2019.
Regional Office Information
• Draft to Isaiah Reed on 4/30/2019 by email.