NCS000389_Staff Report_20100710

NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000389
DAK America
Fayetteville, NC
Facility Activities and Processes:
• SIC Code: 2821— Plastic Materials, Synthetic Resins, and Nonvulcanizeable Elastomers. The site has
between 7 and 8 outfalls (varies with the year) that discharges to the Cape Fear River, a class C stream, in
the Cape Fear River Basin. DAK and Clear Path share outfall #001. DAK has representative outfall status for
outfall #001.
• DAK is principally engaged in the manufacture of polyester chips, which will be used to produce various
plastic items for industrial and/or consumer use. The polyester chips at this facility are manufactured in a
continuous process which utilizes two primary process systems.
• The manufacturing operations occur in the southwest portion of the property in the continuous
polymerization (CP) and the solid-state polymerization (SSP) plant. The railroads located on the
southeastern portion of the property are for the loading of product and unloading of raw materials.
• DAK Americas LLC — Cedar Creek Site is located in the Cedar Creek Industrial Complex.
• Clear Path Recycling is now located on part of the DAK facility. Clear Path is the largest polyethylene
terephthalate (PET) recycling facility in the world. The old Monsanto facility, now Clear Path Recycling,
was used to manufacture Round -Up and is currently a Brownfields site.
• 1,4-Dioxane was added to the monitoring requirements in 2010 as the result of a spill on 7/16/2002. The
permit file included data taken for the previous renewal and the last two samples indicted there was
some 1,4-Dioxane present in stormwater.
• 1,4-Dioxane is a known carcinogen and is a very persistent chemical that does not readily break down. In
this case, an aquatic life -based stormwater benchmark would not be helpful because it has high human
health concerns. For example, the stormwater benchmark would be 1,100 mg/L (calculated % FAV)
compared to the human health -based instream standards of 3.2 ug/I for water supplies and 730 ug/I for
general human health exposures (Class C Waters). A 10-day child exposure rate has been developed for
this chemical of 400 ug/I.
• The facility should be aware of an 1,4-dioxane levels that raise human health concerns. Because of the
previous spill, a benchmark will trigger more investigation or more clean-up, if needed. The Water Supply
standard is not typically used even when receiving waters are WS, because it is not necessarily
appropriate for a stormwater benchmark. This more stringent WS value should be noted. The 10-day child
exposure rate of 400 ug/L be used as the benchmark, as the benchmark reflects a time frame more
consistent with storm events (10 days vs lifetime exposure for the human health/water supply numbers)
and would be protective of the more sensitive population (children).
Monitoring Information:
• The facility has been monitoring for COD, 1,4-Dioxane, pH, and oil and grease.
• Previous permit did have a tier system.
• The facility kept consistent records of monitoring events. However, the facility had exceedances of COD in
2012, 2013, and 2014, in separate outfalls. Some years have no flow. Monitoring appears consistent.
Surface Water Information:
• This section of the Cape Fear River is listed as an impaired water experiencing problems with lead, water
temperature, fecal coliform, copper, cadmium, nickel, pH, arsenic, turbidity, dissolved oxygen, zinc, and
iron.
• There are no TMDL's for this section of the Cape Fear River.
• The 2006 303(d) includes the Cape Fear River 18-(26)c (from Grays Creek to Lock Dam 3) for a Chlorophyll
a violation. This impairment language was not added to the permit because the segment of the Cape Fer
River is not the same segment that the facility discharges into. The City of Fayetteville water supply intake
looks to be about 12 miles upstream.

Discussions with the Facility:
• Discussions began with the facility on 4/02/2019.
Regional Office Information:
• Draft to Mike Lawyer on 4/08/2019 by email.