NCS000389_2010 Staff Report_20100410

NCS000389
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
NPDES Permit Number:
Facility Location:
Type of Activity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification:
Proposed Permit Requirements:
Monitoring Data:
Response Requested by (Date):
Central Office Staff Contact:
Special Issues:
DAK America
NCS000389
3216 Cedar Creek Road, Fayetteville, NC (Cumberland County)
Plastic Manufacture
2821
See Figure 1
Cape Fear River Basin, Sub -basin 03-06-15
WS-IV; CA
See attached draft permit.
See Table 1
Return to: Brian Lowther, [phone]
Issue
Rating Scale: 1(easy) to
10(hard)
Compliance history
6
Benchmark exceedance
6
Location (TMDL, T&E
7
species, etc)
Other Challenges:
8
• Benchmark for 1.4
Dioxane
• Figuring out the site
with 3 owners
Difficulty Rating:
27/40
Special Issues Explanation:
• 1.4-Dioxane was detected in the SW samples. It is a known carcinogen and has human health
concerns. More information on this is below in the analytical monitoring section.
DENR-FRo
APR 0 6 rii
Page 1 of 9

NCS000389
Description of Onsite Activities:
• 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 loading of product and unloading of raw materials.
• DAK Americas LLC Cedar Creek Site is located in the Cedar Creek Industrial Complex. The complex
also houses Dupont Teijin Films; Wellman, Inc (no longer in operation); and the DAK Service Complex (a
utilities facility purchased from Monsanto in January 2004). The Service Center is located east of the
Dupont Teijin film property and supplies utilities for both the DAK Resine Plant and the Dupont Teijin Film
Plant. Utilities include steam, cooling water, demineralized water, and wastewater treatment.
• Clear Path Recycling is now located on part of the DAK facility. Clear Path is the largest PET
(Polyethylene terephthalate) recycling facility in the world. Clear Path Recycling has obtained 53 acres
which was formerly part of DAK Americas 172 acre tract.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File
• Central Files
• EPA Sector -Specific Permit, 2008
• 303(d) List, 2008 draft, 2006 final
• 2005 Cape Fear Basinwide Plan
• DuPont File NCS000056
• TRi Maps data and links.
History:
• August 15, 2003: Permit issued to DAK Resins LLC. Monitoring included i ,4-Dioxatie and COD sampled
annually for lie first three years and quarterly during year four.
• February 2, 2005: Name change to DAK Americas, LLC
• January 25, 2007: Renewal letter sent.
• March 6.2008: Renewal Application received. Asked for SW outfall 003 to be included with their
wastewater permit. This request was denied when the wastewater permit was renewed.
• August 10, 2009. Request to transfer outfalls frotn DAK to Clear Path.
Page 2 of 9

NCS000389
NCS000389
MV Scale 1:24,000
Figure 1: Map of Facility
DAK America LLC
DAK America LLC Cedar Creek Site
Latitude: 340 59' 00" N
Longitude: 780 4730" W
County: Currberland
Receiving Stream: Cape Fear River
Stream Class: WS-IV; CA
Sub -basin: 03-06-15 (Cape Fear River Basin)
Facility Location
1�
Page 3 of 9

NCS000389
Central Office Review Summary:
1. Owner's Other Permits: DAK America wastewater permit NC0003719. The effluent monitoring requirements
include flow, TSS, BOD, NH3-N, Fecal Coliform, Total Residual Chlorine, Temperature, DO, pH, Total
Nitrogen, Total Phosphorus, Acute Toxicity, and Conductivity. Also, have OCPSF parameters.
o Air Quality Title V- 04319T18
o Synthetic Minor Air Permit — 04051 R30
o Permit to Discharge Wastewater Under the Public Works Commision's Industrial Pretreatment Program
(application pending) — 2116RF
Notes on Wastewater permit: our discharge permit for DAK Americas, LLC (formerly Monsanto, Fayetteville) has
stormwater conditions and boilerplate that will need updating for this renewal (unless covered by your permit
NCS000389). Update: the stormwater outfalls were not included in NC0003719 and need to be included in the SW
renewal.
2. General Observations:
• Three companies located within the expansive property.
• The old Monsanto facility, now Clear Path Recycling, was used to manufacture Round -Up.
• Site conditions are such that DAK and Clear Path share one SW outfall (#001). DAK has
representative outfall status for their single #001 outfall. Clear Path has numerous others.
• The site is 26,1 acres with 4.72 acres on impervious
• In the application, Cobalt is listed as a potential pollutant not covered by analysis. Cobalt is in the TRI
for being at the facility. The Cedar Creek site used cobalt as a toner additive. The plant has recently
discontinued its use; however, one 2000-lb tote bin remains on site. It is located inside in the Logistics
Warehouse and will be returned to the manufacturer with the next month.
3. Impairment: The 2006 303(d) includes the Cape Fear River 18-(26)c (from Grays Creek to Lock and Dam 3) for
a Chlorophyll a violation and 18-(26)d (from Lock to Dam 3 to NC41) for a Mercury Fish Advisory. Basinwide
Plan indicates the Cape Fear River 18-(26)b (from Peares Mill Creek to Grays Creek) has turbidity and fecal
coliforni as stressors. The impairment language was not added to the permit because these segments of the Cape
bear are not the same segment of the Cape Fear where the facility's discharges are located.
The City of Fayetteville water supply intake looks to be about 12 miles upstream based on the classified streams
layer is GIS. The stream segment is identified as "From City of Fayetteville water supply intake to mouth of
Hammond Creek."
4. Threatened and Endangered: Based on the Natural Heritage Virtual Workroom there are no federal protected
species within two miles of the facility.
5. Location: Six outfalls flow to the Cape Fear River:
• 001 — 34' 58' 08", -78' 46' 58" — SW from developed and undeveloped land including plant process
areas and cooling tower blowdown.
• 002 — 34 58' 08", -79 46' 58" — Wastewater
• 003 — 34 59' 02", -79 47' 26" — Stormwater runoff from DAK resin plant.
• F — 34 58' 42", -79 46' 50" - SW from developed and undeveloped land. Overflow from SW001
• G — 34 58' 41 ", -79 46' 50" — SW from activities associated with wastewater treatment basins, fuel
storage and paved roadways used for in -plant transportation. The outfall discharges onto a vegetative
strip prior to entering the waterway.
• H — 34 58' 45", -78' 47' 05" — SW from activities associated with the wastewater treatment plant. The
outfall discharges onto a vegetative strip prior to entering the waterway.
6. Industrial Changes Since Previous Permit: None provided.
7. Ana]3 tical Monitoring Notes: The analytical samples in central files are shown in Table 1. A letter was included
to explain a 2040 mg/l COD value. They conducted a visual search for potential contamination and no visual
Page 4 of 9

NCS000389
contaminates were detected. Another sample was taken from the stormwater pond and the value was 13.3 mg/l.
The permittee believes the original sample was invalid.
EPA 2008 Multi Sector -Specific Permit, Sector C for Chemicals and Allied Products: Subsector C4 Plastics,
Synthetics, and Resins (SIC 2821-2824) recommends monitoring for Total Zinc. Zinc will not be added to the
permit because it does not seem to be a pollutant of concern based on the industrial activities of this site.
Based on the last staff report, 1 A —Dioxane was added to the requirements as the result of a previous spill on
7/16/2002. The permit file included data taken for the pervious renewal and the last two samples indicated there
was some 1.4-Dioxane in the stormwater (see Table 1).
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 1100 mg/L (calculated ''/z FAV) compared to the
human health based instream standards of 3.2 ug/L for water supplies and 730 ug/L for general human health
exposures (Class C waters). A 10 day child exposure rate has been developed for this chemical of 400 ug/L.
(Information based on an email from Nikki Remington 2/25/10)
The reviewer recommends that the facility should be aware of any 1,4 - dioxane levels that raise human health
concerns, particularly with a discharge to WS-CA. 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, but the reviewer recommends, the 10 day child exposure rate of 400 ug/L be used as the
benchmark. This benchmark reflects a time frame more consistent with stormwater events (10 days vs lifetime
exposure for the human health/water supply numbers) and would be protective of the more sensitive population
(children); this values seems to be the most appropriate to prompt the facility to respond to a possible problem.
However, if future monitoring detects levels above the WS standard, DWQ may want to investigate potential
WQ standard violations.
Sample results from previous renewal. -
Lead — 0.01 mg/l (benchmark = 0.033 mg/1)
Oil and Grease — 5 mg/1 (benchmark = 30 mg/1)
pH — 7.35 (benchmark = 6-9 su)
TSS — 17 mg/1(benchmark = 100 mg/1)
Data from the previous permit is in Table 1.
Monitoring for NCS000056 -- DuPont Teijin Films included COD, Oil and Grease, and pH.
COD, 1,4 —Dioxane, Oil and Grease, and pH have been added to the permit because they are potential pollutants
onsite. Oil and Grease will be added to make the parameters consistent with the DuPont permit.
8. Qualitative Monitoring Notes: None included in the application.
DENR-FRO
APIR 0 6 2010
DWO
Page 5 of 9

NCS000 389
Table 1: Analytical Monitoring
Required
Sampling
—Range
Sample
Date
Total
Flow
MGD
Precipitation
(in)
Duration
(hours)
1.4- Dioxane
COD
Benchmark:
0.4 m /L*
Benchmark:
120 m /L*
Outfall 003
11/19/2003
0.71
1
2
<0.025
17
614/20041
0.218
0.3
0.67
<0.1
13.3
7/29/2005
2.97
4.2
4
<0.005
10/6/2005
1.9
2.7
36
BDL
13.3
11/8/2006
1.2
1.8
24
211 /2007
1.06
1.5
25.5
13.3
""Over Current Benchmark
Data Not Collected
* Benchmarks not in pervious permit
Page 6 of 9

NCS000 389
Revised Permit Recommendations: Analytical Monitoring:
1. COD and 1,4—Dioxane have been maintained in the permit. Oil and Grease and pl l have been added to the
analytical monitoring requirements. Parameters added because they are potential pollutants and they are
consistent with NCS000056 DuPont which is on the same site.
2. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
3. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stonmwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier I and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.
4. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II Section B. Qualitative monitoring is required regardless of representative
outfall status.
5. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
6. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
7. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part 11 Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part 11 Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part I1 Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and
activities are not exposed to precipitation or runoff as described in 40 CFR §I22.26(g), the facility may qualify
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
is provided in Part I Section A.
Page 7 of 9

NCS000389
Discussions with permittee: Elizabeth Wike at DAK. Office: [phone], Mobile: [phone],
[e-mail]
From email on 2/18/10: Beginning on the west end, the first tract is owned by DAK Americas. This area is the
location of DAK's Resins Plant. The area to the east of DAK's Resins Plant is the Dupont facility. Moving
further to the east is a large tract that reaches from Highway 53 on the north to the Cape Fear River on the south.
The northern portion of this property contains DAK Americas Utilities, the southern portion contains DAK's
wastewater treatment plant. The tract of land on the north east belongs to Clear Path Recycling.
Stormwater outfalls were previously included in DAK's NPDES permit for the wastewater treatment plant for
the outfalls from the DAK Utilities Area, DAK Wastewater Treatment Plant Area, and what is now Clear Path
Recycling. When DAK applied to renew its NPDES permit, DENR decided to remove these outfalls from the
NPDES permit and have them included in the stormwater permit. The stormwater permit application for the
DAK Resins site was submitted a couple of years ago. It only included one outfall from the retention pond
shown on the south east corner of the property. This stormwater from this pond rarely discharges to the Cape
Fear River because most of the water either evaporates or infiltrates to the ground before reaching the overflow
from the pond. The DuPont facility is permitted separately.
Can you tell me how cobalt is used on the site? How much is on site and where it is stored?
From email on 3/23/10: The Cedar Creek site used cobalt as a toner additive. The plant has recently
discontinued its use; however, one 2000-lb tote bin remains on site. It is located inside in the Logistics
Warehouse and will be returned to the manufacturer with the next month.
Page 8 of 9