NC0004308_More Information (Requested)_20220517

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Director of Asset Management Americas
Badin Business Park LLC
Highway 740
P.O. Box 576
Badin, NC 28009
NORTH CAROLINA
Environmental Quality
May 17, 2022
Subject: Request for Additional Information
NPDES Application NC0004308
Badin Business Park
Dear Ms. Robyn L. Gross,
This office reviewed the renewal application for Alcoa (BBP) NPDES permit. Please find below the
modifications required to proceed with the renewal process.
• In Form 2E, section 4, the mass is reported as "#/day" which seems to be a typo. Please correct it
to correct units.
• Please expand on the source of Chlorine reported in Form 2E for outfall 005, while no treatment
system exists. [Note: In the current permit there is a limit for total residual chlorine for outfall
005.]
• Please elaborate on section 5.2 of Form 2E, especially for the ones that list fire protection water.
Please consult EPA Form 2E instructions.
• Please report any missing temperature or other parameters in section 4.2 of 2E Form. Please
consult EPA Form 2E instructions.
• Please explain about your waiver request for lack of discharge in outfall 011 and 019, while the
amended Form 2E of outfall 011 reported 9 MGD flow. The facility can wait for any related
sample collection until end of high precipitation season (summer), but it is better to report the
result as soon as possible.
• Per Form 2F section 4.3, no "control measure and treatment" exist for outfall 005. Considering
the frequent violation of Fluoride (and some Cyanide violations) in the current permitting cycle,
what actions has BBP taken or plans to take to meet the outfall limits? Per the DEQ discussion
with BBP during in -person meeting on March 9th, 2022, in Archdale building, and per condition
B.(2.)2.(a) of current permit a feasibility study can be done to evaluate contamination source
reduction alternatives and end -of -pipe treatment alternatives.
• Please fill all missing items (or correct items) in tables A-D in Forms 2F (all outfalls, as
applicable). Please consult and carefully follow EPA Form 2F instructions.
• During the site visit by DWR staff on March 22nd, we noticed train cars parked on the tracks as
part of a lease to a third party. Please expand on the possible effects of this and other ancillary
activities on stormwater from drainage areas (such as 2, 3 and 4) and corresponding outfalls.
AROLINA '
omm ep..orEMr nment o�.i
DE
NORTH C
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

What Best Management Practices (BMPs) are in place to minimize the possible adverse effects
on outfalls?
• Also, during the site visit the BBP staff mentioned about the rehabilitation needed for
impoundment in brick closed landfill, discharging to outfall 019. Please elaborate on mentioned
plans, and its possible effects on outfall 019.
Any possible required analysis should be done by a certified laboratory similar to those required by
NPDES permits pursuant to 40 CFR 136.
We appreciate your kind attention to these matters and look forward to continuing to work with you on
this permit renewal. To avoid unnecessary delays please remember per 15A NCAC 02H .0107(b),
additional information must be provided within 60 days of request. Pending review and evaluation of
provided information, further action or additional information may be required.
If you have any questions, please contact at 919-707-3704 or email at [e-mail].
Sincerely,
DocuSigned by:
awlivL ssutn, ftAptia
6258FEA6822C486...
Amirhossein (Amir) Rezaei Adaryani, PhD
Environmental Engineer I
Industrial NPDES Permitting Unit
cc: NPDES Files [Laserfiche]
Douglas Dowden [[e-mail]]
Mooresville Reginal Office/Water Quality, Corey Basinger [[e-mail]]
Anna Gurney [[e-mail]]
D_E
NORTH CAROLINA
gaparhneM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000