NC0023876_Pretreatment_IUP_Additional_Information_Request_20240130

DocuSign Envelope ID: C5D276D5-08F9-44D3-AD90-E54047C4FC01
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
1/30/2024
Via Electronic Mail (bpattersonkci.burlin on.nc.us)
Mr. Robert Patterson, Jr., P.E.
Water Resources Director
City of Burlington
P.O. Box 1358
Burlington, NC 27216
Subject: Pretreatment Review of New Industrial User Pretreatment Permit Submission
Program: City of Burlington
WWTP: South Burlington WWTP
NPDES #: NC0023876, Alamance County
Dear Mr. Patterson:
The Municipal Unit of the Division of Water Resources has reviewed the following New Industrial User
Pretreatment Permit (IUP) submitted by the City of Burlington received January 25th, 2024.
IUP # I SIU NAME
0091 1 Mount Vernon Chemicals, LLC dba Apollo Chemical - Burlington
The Division requests the following changes and additional information responses for the submitted IUP,
which was signed January 24th, 2024.
Industrial User Wastewater Survey & Permit Application -
• Part 1, Item 4 - 6 types of Biocides are listed, BIOCIDE WORKSHEETS are not provided.
• Part 1, Item 11- Plant Layout Schematic notes an area as "Dry Blending," which is a process
subject to 40 CFR 417 - Please clarify, see comment below.
• Part III, Item 1- No flow equalization volume is documented.
• Waste Pollutant Checklist - Chloride checked present without discharge annotation.
• Data Summary Form - Flow is not metered or estimated.
• Part V, Waste Reduction - No mention of any operating practices to reduce effluent 1,4-D
discharge. Or what chemicals are stored on -site or processes which may contribute 1,4
dioxane to the wastewater plant.
Industrial User Permit -
Front Page - Verify if subject to 40 CFR 414 and/or 417 [also define subpart(s)].
Part 1, Section F. (Limits Page) - Weekly grab samples for 1,4-D is not adequate based on
the sporadic indirect discharge events and potential for wastewater pass through. Industry
should complete daily and POTW weekly grab sampling.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CARCLINA
919.707.9000

DocuSign Envelope ID: C5D276D5-08F9-44D3-AD90-E54047C4FC01
• Part 1, Section F. (Limits Page) - 3 limited metals, Chromium, Copper, and Nickel, are
declared "Absent at Facility" in the application, and yet those noted "Present at Facility" are
not limited. Please clarify.
• Part 1, Section F. (Limits Page) - Add COD.
• Part 1, Section F. (Limits Page) - If subject to 40 CFR 417, must add BOD7, see below.
• Part 1, Section F. (Limits Page) - Monitoring for Quaternary Ammonium Compounds
(because of toxicity for biological treatment processes).
• Part III, Item 1. - Corrections need for bullets.
• Part III, Item 5. - Include an enforceable compliance schedule including requirements for
On -site inspection by POTW.
Supplemental Requirements and Information Needed -
Apollo Chemical Company shall provide a letter concerning applicability of effluent guidelines
for BOTH, 40 CFR 414 - Organic Chemicals, Plastics, and Synthetic Fibers, and 40 CFR 417 -
Soap and Detergent Manufacturing Point Source Category. It's not clear from the information
provided whether the indirect discharge falls under either category.
Apollo Chemical should also collect a daily composite sample and hold the sample until the
results from the WWTP indicate the need for analysis of the stored sample. This is similar to
the process used to assess the contribution of 1,4 dioxane to the wastewater treatment
plant.
• The City of Burlington shall document evaluation of all Apollo Chemical Company Safety
Data Sheets (SDSs) for pollutants of concern and include findings in the IUP Part 1, Section
F. (Limits Page). Example is "quaternaries," as stated in the application because of the
known toxicity to biological treatment organisms.
• The City of Burlington shall provide the plan on how monitoring duties will be allocated between
the SIU and the POTW.
• The City of Burlington is obligated to identify and control slug discharges as per 403.8(f)(2)(vi).
Please provide the Division with this plan and findings.
The Division requests this information to be provided within 30 days, however due to the nature of the
circumstances we are requesting a more expedited reply. To summarize this requirement as stated in 15A
NCAC 02H .0917 (g)(2), a request for more information shall be made within 30 days of the Division's
receipt of the permit under Rule .0916 of this Section and shall suspend the 30 day review period in
Paragraph (d) of this Rule; When the Division staff has obtained the requested records or portions of
the record, the Division staff shall have an additional 30 days for review.
If you have any questions or comments, please contact Keyes McGee at [phone] [email:
keyes.mc eendeq.nc.gov]. Thank you for your continued support of the Pretreatment Program.
tkm/burlington_south iup_085_Apollo_adi
Ec: Municipal Unit File
Kristy King, Pretreatment Coord.
Jenny Graznak, WSRO
Central Files (Laserfiche)
Sincerely,
Docu Signed by:
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Michael Montebello, Secion Chief
NPDES Permit Branch
Division of Water Resources
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
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