NC0023876_Pretreatment_Response_Letter_20240215 (2)

PASSION FOB PERFECTIONCHEMICALS. LLC
14-Feb-2024
Robert C. Patterson
City of Burlington — Water Resources Department
1302 Belmont Street
Burlington, NC 27215
Dear Mr. Patterson:
In response to your "Request for Information — Permit Application" dated 1-Jan-2024, see Mount
Vernon Chemicals, LLC dba Apollo Chemical below.
Industrial User Wastewater Survey & Permit Application -
1. Part 1, Item 4-6 types of Biocides are listed, BIOCIDE WORKSHEETS are not provided
Please fill out a Biocide Worksheet for each Biocide listed.
• See the included Worksheets along with the SDS and technical information for
the six Biocides listed in the IUP Application.
i. ChemTreat CL2150
ii. BIT-20
iii. Kathon CG-ICP
iv. BioBan DXN
v. Preventol P-91
vi. Nuosept 95
2. 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. Please describe
the "Dry Blending" process and explain how Apollo does or does not fall into the
category of 40 CFR 417.
On the schematic layout the noted area is called "Old Dry Blending" area. The
prior owner of the facility used this area for Dry Blending. When the facility was
purchased by Apollo Chemical, the equipment used for the dry blending was
removed. No dry blending operations have been conducted by Apollo Chemical
and no such operations are currently conducted at Apollo Chemical's Burlington
facility. This area is currently used by Apollo Chemical for storage of containers,
raw materials, and finished goods. A clarification note was added to the IUP
Permit Application.
• See continued explanation under the "Industrial User Permit" item 1, below.
3. Part III, item 1 - No flow equalization volume is documented Fill in the volume of Apollo's
holding tank.
Mount Vernon Chemicals dba Apollo Chemical
2001 Willow Springs Lane, Burlington, North Carolina 27215
Tel : [phone]
mzavaaliaCdaoollochemical.com
www.apollochemical.com
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MOUNT VERNON
CHEMICALS , L L C
• Apollo Chemical has one 900-gallon equalization tank with a 5,000-gallon
overflow holding tank (total volume 0.0059 million gallons) — Total Volume of
Equalization was included on the IUP Permit Application.
4. Waste Pollutant Checklist- Chloride checked present without discharge annotation. Mark
if chloride is present or absent in the discharge.
• The main chloride that may be present is in the form of salt NaCl. In the cleaning
process a few of our products may need cleaning with bleach at approximately
0.06% bleach added to the vessel cleaning water. Chloride was marked as
present in the discharge on the [UP Permit Application.
5. Data Summary Form -Flow is not metered or estimated Fill in the flow. You can use the
estimated values you calculated from PART II, Water Supply, Use, & Disposal
Worksheet.
• From Part II, Water Supply, Use, and Disposal Worksheet, the Estimated
Average gal/day value of 22,954 gal/day was used.
6. 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. Update this section with your findings and efforts to
reduce 1,4 Dioxane.
Apollo Chemical is currently evaluating its processes to understand
potential source(s) of 1,4-Dioxane in its wastewater. Apollo Chemical hired
a third -party consultant to assist in this evaluation and has been working
closely with the City of Burlington. Through this evaluation, Apollo
Chemical believes certain manufacturing processes are associated with
elevated 1,4-Dioxane in wastewater. Apollo Chemical also believes that
the intake water provided by the City of Burlington, at times, contains
elevated 1,4-Dioxane concentrations that are passed through to Apollo
Chemical's wastewater.
• Apollo Chemical is currently segregating and containerizing for disposal (1)
the distillate generated by certain processes and (2) the rinse/cleaning
liquid used to clean the process vessels. These operational changes are
believed to reduce the amount of 1,4-Dioxane in wastewater effluent.
• Apollo Chemical continues to consider methods for reducing 1,4-Dioxane
in the wastewater effluent.
• Apollo Chemical will actively identify and minimize sources of 1,4-Dioxane
in the wastewater effluent by raw material selection and process
evaluations.
• New product introductions will include efforts to identify possible sources of
1,4-Dioxane.
Industrial User Permit -
Mount Vernon Chemicals dba Apollo Chemical
2001 Willow Springs Lane, Burlington, North Carolina 27215
Tel: [phone]
mzavaoIiapapollochemical.com
www.apollochemical.com
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MOUNT VERNON
E M I C A L S L L C
C 1�
1. Front Page- Verify if subject to 40 CFR 414 and/or 417 [also define subpart(s)]. In
addition to explaining if Apollo is or is not subject to 40 CFR 417, describe how Apollo
does or does not fall into the category of 40 CFR 414.
• Please see Apollo Chemical's February 14, 2024 letter regarding the
inapplicability of Parts 414 and 417.
2. 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. Update the Wastewater Pollutant Checklist with Chromium,
Copper, and Nickel as being present at the facility. Explain why they might be present in
your effluent. The City of Burlington tested Apollo's effluent for the following metals on 26
September 2023. Include this information in the Wastewater Pollutant Checklist.
• Nickel, Zinc, Copper, and Chromium are not currently added or otherwise known
to be used in Apollo's operations.
• Zinc was previously used as a catalysis in one product. This product has not
been produced since 2018.
• As to the testing performed by the City, Apollo Chemical is not certain of the
precise source of these detections. The metals Nickel, Zinc, Copper, and/or
Chromium could be coming from the galvanized, carbon steel, and/or SS pipes
and vessels. Facility supply water could also contain these compounds.
Metal
Concentrations
(mg/1)
Nickel
0.00575
Zinc
0.0022
Copper
0.01237
Chromium
0.00725
3. Additionally, in the Wastewater Pollutant Checklist section of your application, Antimony,
Mercury, Chloroform, Toluene, and Xylene are marked as being present at the facility.
Explain if these pollutants are present in the discharge. If not, explain how they are
disposed.
• Antimony is used as a catalysis for one product at 0.00057%. Antimony could be
in the vessel cleaning water at trace levels sent to the wastewater effluent.
• An infrequently used reagent used in a QC test method contains a small amount
of Mercury. The spent sample is sent to the wastewater effluent. No Mercury is
used in the manufacture of a product.
Mount Vernon Chemicals dba Apollo Chemical
2001 Willow Springs Lane, Burlington, North Carolina 27215
Tel: [phone]
mzavagliaCalapollochemical.com
www.apollochemical.com
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MOUM VERNON
CHEMICALS , L L C
• Chloroform is used as a solvent for preparing QC samples. The spent sample is
evaporated to remove the Chloroform. The spent sample is not sent to the
wastewater effluent.
• Toluene has been eliminated in our QC testing and replaced by Xylene. The UP
application has been revised to reflect this change.
• Xylene is used as a solvent in a QC test method. The spent sample is sent to
the wastewater effluent. No Xylene is used in the manufacture of a product.
• See revised IUP Application.
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. As stated previously, please explain how Apollo Chemical does or does not fall
into these categories.
• Apollo Chemical has provided a February 14, 2024 letter regarding the
inapplicability of Parts 414 and 417.
2. 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 UP Part 1,
Section F (Limits Page). Example is "quaternaries," as stated in the application because
of the known toxicity to biological treatment organisms. Please provide your SDSs for
review.
• A SharePoint link to our SDSs will be provided. This information should be
considered confidential business information and not distributed.
Sincerely,
N
Mike Zavaglia
Mount Vernon Chemicals, LL ' dba Apollo Chemical
Executive President Mount Vernon Chemicals, LLC
Mount Vernon Chemicals dba Apollo Chemical
2001 Willow Springs Lane, Burlington, North Carolina 27215
Tel : [phone]
mzavaalia(a�apollochemical.com
www.a ool lochemica I. com
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