NC0023876_Pretreatment_Response_Letter_20240215

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P A S S I O N FOR PERFECTION.
February 14, 2024
Robert C. Patterson
City of Burlington — Water Resources Department
1302 Belmont Street
Burlington, NC 27215
RE: Inataalicability of 40 CFR Parts 414 and 417 to Apollo Chemical
Dear Mr. Patterson:
In further response to the City of Burlington's January 1, 2024 Letter, Mount
Vernon Chemicals LLC, d/b/a Apollo Chemical submits this letter further describing the
inapplicability of the categorical standards contained in 40 CFR Parts 414 and 417.
As previously explained, Apollo Chemical's primary registered U.S. Department of
Commerce Bureau of the Census Standard Industrial Classification (SIC) is 2843
(included under primary NAICS 325613) - (Surface Active Agents, Finishing Agents,
Sulfonated Oils, and Assistants). Apollo Chemical is appropriately described as an
establishment primarily engaged in producing surface active preparations for use as
wetting agents, emulsifiers, and penetrants. Apollo Chemical manufactures products like
flame retardants, stain blockers, defoamers, moisture management products, repellants,
lubricants, binders, and soil release agents. Apollo Chemical's operations are not subject
to 40 CFR Parts 414 or 417 as explained further below.
Inapplicability of Part 414 —Organic Chemicals, Plastics, and Synthetic Fibers Point
Source Category
Apollo Chemical's operations are not subject to 40 CFR 414. Section 414 applies
to establishments that manufacture the organic chemicals, plastics, and synthetic fibers
(OCPSF) products or product groups covered by subparts B through H of 40 CFR 414
and are included within the following major groups:
(1) SIC 2821—Plastic Materials, Synthetic Resins, and Nonvulcanizable
Elastomers,
(2) SIC 2823—Cellulosic Man -Made Fibers,
(3) SIC 2824—Synthetic Organic Fibers, Except Cellulosic,
(4) SIC 2865—Cyclic Crudes and Intermediates, Dyes, and Organic Pigments,
(5) SIC 2869—Industrial Organic Chemicals, Not Elsewhere Classified.
Mount Vernon Chemicals dba Apollo Chemical
2001 Willow Springs Lane, Burlington, North Carolina 27215
Tel : [phone]
mzavagliaCa�apollochemical.com
www.aoollochemical.com
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MOUNT VERNON
CHEMICALS , L L C
40 CFR § 414.11(a). Apollo Chemical's operations are properly classified under SIC
2843. Accordingly, Apollo Chemical is not subject to requirements of Part 414 as SIC
2843 is not one of the included major groups identified by 40 CFR § 414.11(a).
Additionally, Apollo Chemical does not manufacture the products listed in 40 CFR
414, Subparts B — Rayon Fibers; Subpart C — SIC 2823 cellulosic man-made fibers, and
SIC 2824 synthetic organic fibers; Subpart D — SIC 28213 thermoplastic resins; Subpart
E — SIC 28214 thermosetting resins; Subpart F — SIC 2865 & 2869 commodity organic
chemicals; Subpart G — SIC 2865 and 2869 bulk organic chemicals and bulk organic
chemical groups; or Subpart H — SIC 2865 and 2869 special organic chemicals. As to
Subpart G, Apollo Chemical does not manufacture the pure bulk organic chemicals
referred in section 414.70 list of subcategories (a) (b) (c) (d) or (e).
Subparts I and J — Direct Discharge Point Sources that Use End of Pipe Biological
Treatment and Direct Discharge Point Sources that Do Not Use End of Pipe Biological
Treatment (respectively) are not applicable to Apollo Chemical where, as stated above,
Apollo Chemical's operations do not fall under any of the "product groups defined by §
414.1 V and Apollo Chemical does not directly discharge its wastewater. See 40 CFR §§
414.90; 414.100 Subpart K does not apply where, as stated above, Apollo Chemical's
operations do not fall under any of the "product groups defined by § 414.11." See 40 CFR
§ 414.110. Accordingly, Apollo's operations are not subject to 40 CFR Part 414.
Inapplicability of Part 417 — Soap and Detergent Manufacturing Point Source
Category.
Apollo Chemical's operations are not believed to be subject to 40 CFR 417 where
Apollo is not engaged in the manufacture of soap or detergent. Part 417 Subparts I
through M relate to certain sulfonation processes specific to soap and detergent
manufacturing. While Apollo Chemical utilizes sulfonation at its Burlington plant, it does
not engage in the sulfonation processes related to soap and detergent manufacturing.
Additionally, Apollo does not engage in the sulfonation processes described by Part 417
(See Subpart I — Oleum Sulfonation and Sulfation; Subpart J — Air S03 Sulfation and
Sulfonation; Subpart K — SO3 Solvent and Vacuum Sulfonation; Subpart L — Sulfamic
Acid Sulfation; Subpart M — Chlorosulfonic Acid Sulfation).
The City recently requested that Apollo Chemical clarify the use of an area noted
as "old dry blending area" on a plant schematic and suggested that dry blending may be
a process subject to Part 417. The prior owner of the Apollo Chemical facility used this
area for dry blending. When the facility was purchased by Apollo Chemical, the
equipment used for dry blending was removed. No dry blending operations have been
Mount Vernon Chemicals dba Apollo Chemical
2001 Willow Springs Lane, Burlington, North Carolina 27215
Tel: [phone]
mzavagliaC, ".Ilochemical.com
www.apollochemical.com
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MOUNT VERNON
CHEMICALS, L L C
conducted by Apollo Chemical and no such operations are currently conducted at Apollo
Chemical's Burlington facility. Moreover, Apollo Chemical does not manufacture
detergents, making Subpart Q — Manufacture of Detergents by Dry Blending —
inapplicable.
Please let Apollo Chemical know if you have any questions concerning the above.
Sincerely,
N
Mike Zavaglia
Mount Vernon Chemicals, Ilc dba Apollo Chemical
Executive President Mount Vernon Chemicals, Ilc
Mount Vernon Chemicals dba Apollo Chemical
2001 Willow Springs Lane, Burlington, North Carolina 27215
Tel: [phone]
mzavaa IiaC'aoollochemical.com
www.apollochemical.com
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