NC0003719_Biological Assessment_20091230

DAK Ar iericas
FIBERS, MONOMERS & RESINS
December 30, 2009
Mr. Joe Corporon
Division of Water Quality
NC Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh NC 27699-1617
Subject: DAK Americas LLC — Cedar Creek Site
NPDES Permit No.: NC0003719
'NCO
MN 1 3 2u'e
DWQ
Dear Mr. Corporon:
September 4, 2009 the DAK Americas LLC Cedar Creek site's NPDES permit was issued with
Section A.(5.) Plastics Recycling Facility (PRF) — Waste Characterization requesting a written
report, anticipating the character of PFR wastes generated under SIC 5162, and specifically
identifying:
1. waste chemical character and methods used to identify, quantify, and characterize wastes,
2. waste treatability by existing onsite WWTP processes
3. examples of character of wastestreams from similar active/operating SIC 5162 PRFs
4. any anticipated interference by PRF wastes with existing wastestream treatability
5. any new treatment units identified or processes requiring ATC.
Enclosed please find the Biological System Assessment Report which describes the character of
wastewater from Clear Path Recycling LLC, the plastics recycling facility under construction
adjacent to the DAK Americas facility in Fayetteville, North Carolina. Items 1,2, 4, and 5 are
included in this report. No new treatment units or processes requiring ATC are required at
DAK's WWTP to treat the process wastes from the Clear Path Recycling facility. The
anticipated start up date is April 1, 2010.
As for Item No. 3 above, no examples of similar active/operating PRFs discharging directly to
surface waters have been identified.
If you have any questions, please call me at [phone] in my office or at [phone] on
my cell phone.
Sincerely,
Elizabeth Wike
Environmental Engineer
DAK Americas LLC
3500 Daniels Road, N.E. • Leland, NC 28451
1-877-432-2766

BIOLOGICAL SYSTEM ASSESSMENT REPORT
DAK AMERICAS, LLC
3216 CEDAR CREEK ROAD
FAYETTEVILLE, NORTH CAROLINA 28312
EnSafe Project Number
0888806412•
JAN 1 3 2010 Prepared for:
DAK Americas, LLC
3216 Cedar Creek Road
Fayetteville, North Carolina 28312
Prepared by:
EJIISAFE
EnSafe Services, P.C.
5724 Summer Trees Drive
Memphis, Tennessee 38134
[phone]
[phone]
www.ensafe.com
N.C. Firm License No. C-1440
November 2009

Site Name:
Site Location:
Biological System Assessment Report
DAK Americas, LLC
3216 Cedar Creek Road
Fayetteville; North Carolina 28312
Site Contact Information:
Ms. Elizabeth Wike
DAK Americas, LLC
3216 Cedar Creek Road
Fayetteville,,North Carolina 28312
Engineer Contact Information:
Mr.. David Hutson, P.E
EnSafe Inc.
220 Athens Way, Suite 410
Nashville; Tennessee. 37228
(615) 255=9300
[e-mail]
Seal and Signature of Certifying PE
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0307 2

Table of Contents
1.0 INTRODUCTION 1
1.1 General 1
1.2 NPDES Permit 2
1.3 PWC Permit 5
1.4 .Existing IWTP Details 6
2.0 FLOW RATE ASSESSMENT 10
2.1 Phase I Start -Up Flow Rate 10
2.2 Phase I Flow Rate 10
2.3 Future Phase II Flow Rate 11
3.0 WASTEWATER SOURCES AND ANALYTICAL CHARACTERIZATION 13
3.1 PET Bottle Recycle Wastewater Samples for Testing 13
3.2 Existing Facility Wastewater Samples for Testing 15
3.3 Simulated Pretreatment System Effluent 17
4.0 BIOLOGICAL TREATABIL1 Y STUDY 19
4.1 Materials and Methods 19
4.2 Data Summary 23
4.3 PET Bottle Recycle Wastewater Slug 27
5.0 DETERMINATION OF BIOKINETIC COEFFICENTS 29
5.1 Temperature 33
6.0 BIOLOGICAL TREATABIL1 Y ASSESSMENT 37'
6.1 Selected Sludge Age 37
6.2 Design Cases Evaluated 37
6.3 Projected MLVSS Concentration 38
6.4 Oxygen Requirement 42
6.5 Existing Aeration Capacity Assessment 44
6.6Estimated Sludge Production 49
6.7 Evaluation of Existing Clarifier 52
7.0 CONCLUSIONS AND RECOMMENDATIONS 54

Tables
Table 1 Estimated Effluent Warm Season BOD and TSS Concentration Limits as a Function
of Flow 4
Table 2 Estimated Warm Season Concentration Limits as a Function of Flow 5
Table 3 PWC Conventional Permit Limits 5
Table 4 Existing IWTS — Operational Assessment 8
Table 5 Summary of Flow Conditions 12
Table 6 PET Bottle Recycle Wastewater Characterization 14
Table 7 Existing Facility Wastewater Characterization 15
Table 8 Plant Operation Data Comparison 16
Table 9 Existing Facility Wastewater Characterization 17
Table 10 Pretreated Wastewater Metals and Cyanide Results 18
Table 11 Sludge Wasting Summary 22
Table 12 Reactor Parameter Summary 23
Table 13 • Estimated Reactor Sludge Ages 24
Table 14 Reactor Analytical Data 25
Table 15 Reactor Analytical Data 25
Table 16 Reactor SOUR and SVI Data 26
Table 17 Estimated Influent Temperature 34 •
Table 18 Estimated Influent Temperature 35
Table 19 Case Al: Estimated Aeration Basin VSS Concentrations 39
Table 20 Case A2:. Estimated Aeration Basin VSS Concentrations 40
Table 21 Case B1: Estimated Aeration Basin VSS Concentrations 41
Table 22 Case B2: Estimated Aeration Basin VSS Concentrations 41.
Table 23 Case Al: Oxygen Requirements 42
Table 24 Case A2: Oxygen Requirements 43
Table 25 Case B1: Oxygen Requirements 43
Table 26 . Case B2: Oxygen Requirements 43
Table 27 Case Al: Aeration Capacity Assessment 47
Table 28 Case A2: Aeration Capacity Assessment 47
Table 29 Case B1: Aeration Capacity Assessment 48
Table 30 Case B2: Aeration Capacity Assessment 48
Table 31 Case B1: Estimated Solids Production 51
Table 32 Case B2: Estimated Solids Production 51
Table 33 Summary of Cases Evaluated 56
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendices
NPDES Permit and Rationale
Reactor MLVSS vs. Time
Reactor Operational Data
Biokinetic Constant Calculations
Aeration Calculations
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ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
1.0 INTRODUCTION
1.1 General
EnSafe Inc. has prepared this biological treatment assessment report based on information
provided by DAK Americas, LLC, (DAK) and Clear Path Recycling, LLC (CPR).
CPR is proposing to construct a polyethylene terephthalate (PET) recycling plant at the existing
Cedar Creek site. Currently, DAK and DuPont Teijin Films (DuPont) operate production facilities at
this site. Monsanto formerly operated a Roundup production facility that ceased operations
in 2002/2003.
The existing industrial .wastewater treatment plant (IWTP) currently receives and treats DAK and
DuPont process wastewater, sanitary wastewater, and some storm water. Non -contact
cooling water and other existing facility storm water bypass this treatment system and combine
with the IWTP-treated'.efuent prior to discharge. The effluent is discharged to the Cape Fear River
(National Pollutant Discharge Elimination System [NPDES] Permit NC0003719) and/or to the
City of Fayetteville Public Works Commission (PWC) publicly owned treatment works (POTW),
covered under Significant Industrial User Discharge Permit #2116RF. •
The DAK and DuPont process wastewater is regulated under Title 40 Code of Federal Regulations,
Part 414 (40 CFR414) — Organic Chemicals, Plastics and Synthetics Fibers Category (OCPSF). The
PET bottle recycle wastewater is not subject to federal categorical standards.
The IWTP is a conventional activated sludge biological treatment system. The plant was designed
for a flow rate of 1.25 million gallons per day (MGD); although other specific process design
information is not available. The system contains two separate aeration basis, with volumes of
1.2 MG and a 4.4 MG, or a total of 5.6 MG of aeration capacity. EnSafe understands after the
closure of the Monsanto facility, the 4.4 MG aeration basin was taken offline and idled due to the
decrease in flow rate.
The characteristics of the PET bottle recycle wastewater are significantly different than the
organic chemical wastewater currently generated. Based on a literature review of the
general characteristicsof this •wastewater; the main differences relative to the existing
organic chemical wastewater are:
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ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
• High pH;
• High Total Suspended Solids (TSS);
• High Total Dissolved Solids (TDS);
• Presence of non-ionic surfactants;
• Presence of particulate chemical oxygen demand (COD); and
Higher temperature
Considering the different characteristics, the PET bottle recycle wastewater will be pretreated
prior to discharge to the existing IWTP. A detailed discussion of the pretreatment system is
provided , in the Pretreatment System Engineering Report (September 2009). The main
treatment objectives of the pretreatment system are equalization, pH neutralization and
TSS removal, in particular fixed (or inert) suspended solids which are not readily biodegradable.
The TSS containsa high percentage of volatile suspended solids (VSS) which are expected to be
relatively biodegradable based on a literature review.
The assessment consisted of a biological treatability study to assess the' treatability of the
pretreated PET bottle recycle wastewater blended with the existing wastewater at a ratio based on
the projected flow rates provided by CPR and the 2006 to 2008 daily average flow rate. For this
assessment, six bench -scale biological reactors were operated for a period of approximately
7 weeks. Analytical data sheets are included on a CD provided with this report.
1.2 NPDES Permit
In accordance with the terms and conditions of the existing NPDES permit, DAK applied for a
NPDES permit renewal that included the estimated flow contribution from the proposed
PET bottle recycling facility. EnSafe received a copy of this permit from DAK in August 2009. A
copy of the permit and rationale is provided as Appendix A.
Based on a preliminary review of this permit, EnSafe understands the following:
• The permitted flow rate remains 0.500 MGD as a monthly average.
• A 2-year permit was issued that expires on October 31, 2011.
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Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
• The North Carolina Department of Environment and Natural Resources.— Division of Water
(NCDENR) denied the request to include the PET bottle recycle wastewater in recalculating
permit limits, effectively allocating "zero" biochemical oxygen demand (BOD) and TSS to
this new wastestream.
• It appears the NCDENR calculated mass -based BOD and TSS permit limits using "only" the
OCPSF Tong -term average flow of 0.228 MGD, and using the daily maximum and
monthly average concentration limits for BOD (64 milligrams per liter [mg/L] and 24 mg/L,
respectively) and TSS (130 mg/L and 40 mg/L, respectively) in 40 CFR 414, Subpart D. For
BOD, these values were used to calculate seasonal mass -based limits from April 1 to
October 31 (i.e., warm season); then these warm season BOD limits were doubled to
calculate the seasonal mass -based limits for the cool season (November 1 to March 31).
TSS Limits
TSS Daily Maximum: 130 mg/L x 0.228 MGD x 8.34 = 247 pounds per day (Ibs/day)
TSS Monthly Average: 40 mg/L x 0.228 MGD x 8.34 = 76 pounds per day
BOD Warm Season Limits (April 1 to October 31)
BOD Daily, Maximum: 64 mg/L x 0.228 MGD x 8.34 = 122 pounds per day
BOD Monthly Average: 24 mg/L x 0.228 MGD x 8.34 = 46 pounds per day
BOD Cool Season Limits (November 1 to March31)
BOD Daily Maximum: 122 poundsper day x 2 = 244 pounds per day
BOD Monthly Average: 46 pounds per day x 2 = 92 pounds per day
• With this NCDENR permitting approach (i.e., "zero" BOD and TSS allowance for the
PET bottle recycle wastewater), as the discharge flow rate increases the required BOD and
TSS effluent concentration to meet the mass -based limits decreases proportionally.
As an example, the estimated effluent BOD and TSS concentrations that would be required
to meet the mass -based limits as a function of effluent flow are provided in Table 1.
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Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
• November 2009
Table 1
Estimated Effluent Warm Season BOD and
TSS Concentration Limits as a Function of Flow
Daily Max. Monthly Avg. Daily Max. Monthly Avg.
Flow , - BOD Limit BOD Limit TSS. Limit TSS Limit
(MGD) (mg/L) (mg/L) (mg/L) (mg/L)
• 0.228 - 64 24 130 40
0.300 48.6 18.2. 98.9 30.4
0.400 36.5 13.7 74.1 22.8
0:500 29.2 10.9 59.2 18.2
It is not exactly clear how the NCDENR calculated ammonia effluent limits; however, there
was a significant reduction' in the- discharge limit compared to the previous permit. The
previous permit dated February 26, 2003, had the following ammonia limits at a permitted
flow of 0.500 MGD.
Ammonia Warm Season Limits (April 1 to October 31)
Ammonia Daily Maximum: 35 Ibs/day
Ammonia Monthly Average: 70 Ibs/day
Ammonia Cool Season Limits (November 1 to March 31)
Ammonia Daily Maximum:. 70 Ibs/day
Ammonia Daily Average: 140 Ibs/day
• The revised permit limits are as follows:
Ammonia Warm Season Limits (April 1 to October 31)
Ammonia Daily Maximum: 13 Ibs/day
Ammonia Monthly -Average: 26 Ibs/day
Ammonia Coo/ Season Limits (November 1 to March31)
Ammonia Daily Maximum: 26- Ibs/day
Ammonia Daily Average: 52 Ibs/day
As with BOD and TSS, EnSafe estimated the concentration limits at various flow conditions
to achieve the mass based ammonia permit limits. This summary is provided as Table 2.
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EllISAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
Table 2
Estimated Warm Season Concentration Limits as a Function of Flow
Daily Maximum Monthly Average
Flow (MGD) Ammonia Limit (mg/L) Ammonia Limit (mg/L)
0.228 13.66 6.83
0.300 10.38 5.19
0.400 7.78 3.89
0.500 6.22 3.11
• Total phosphorus and total nitrogen are "report only" parameters; there is no permit limit.
• Pass/fail acute toxicity testing is required quarterly with the test species
Pimephales promelas (fathead minnow), using a 24-hour static test at a 90% effluent
concentration. Should any quarterly monitoring event indicate a failure to meet specified
limits, then monthly monitoring will be required until such time that a test is passed.
Upon passing, the monthly requirement will revert to quarterly.
• There is no limit for TDS.
• The permittee shall discharge no foam other than in trace amounts.
1.3 PWC Permit
A review of the PWC permit issued January 1, 2009, allows for a maximum of 75,000 GPD. of
discharge to the POTW. The permit limits for conventional parameters are summarized in Table 3.
Parameter
Table 3
PWC Conventional Permit Limits
Daily Maximum
Limit (mg/L)
Monthly Average ,
Limit (mg/L)
CBOD (Carbonaceous Biochemical Oxygen Demand) 25
TSS — 25
Ammonia 3
Oil and Grease 250
Total Phosphorus 3
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ENSiFE
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Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009.
1.4 Existing IWTP Details
As noted above, the existing wastewater treatment system was originally designed with
two aeration basins at a design flow of 1.25 MGD. As a result of the reduced flow and load
compared to the original design condition, Aeration Basin #1 (AB1) with a volume of 4.4 MG was
taken offline approximately 5 to 7 years ago and idled. Aeration Basin #2 (AB2) with a volume of
the 1.2 MG is currently in operation. Because flow and load are reduced from the original design
capacity of 1.25 MGD, the IWTP currently has both operating and idle components:
Operating Components
• Equalization .and storage
— Two 660,000-gallon, open -top fiberglass_ tanks
• pH adjustment pit
- Urea and phosphorus are added
— Steam is utilized primary from October through April to maintain the aeration basin
temperature .
• Aeration Basin No. 2
- 1,200,000-gallon activated sludge treatment unit
- Five low -speed, mechanical surface aerators
- Two 75-horsepower (hp) floating subsurface aerators (Aire-02 Triton)
• Circular Clarifier
— 90-foot (ft) diameter by 14-ft sidewall depth
- Eimco Type C2D (670,000 gallons)
- Dual polymer flocculation system
o GE PC1224 and GE IC1172
• Aerobic Digester
- 375,000-gallons
Operated as anoxic digester
- Aerators used for mixing to transfer sludge to Sludge Thickener
•
• Sludge Thickener
— 1,000,000 gallons
- Operator controlled decanting to AB#1
Aerators used for mixing to transfer sludge to Sludge Drying Beds
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Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
• Sludge Drying Beds
— Four at 200 ft by 30 ft, total surface area 24,000 square feet (ft2)
Idle Components (out of service five to seven years)
• Aeration Basin No. 1
- 4,400,000-gallon activated sludge treatment unit
- One, 75-hp floating subsurface aerators (assume Aire-02 Triton)
— Five, 75-hp high-speed floating surface aerators
— One, 50-hp high-speed floating surface aerator
To evaluate the existing biological treatment system operation, EnSafe analyzed the
existing operational data from 2006 through 2008. For this assessment, system
operational parameters were calculated and are summarized in Table 4. This data provides
key information in assessing the existing capacity of the system.
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ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
Parameter
Table 4
Existing IWTS - Operational
Units
Assessment
2006
2007 2008
Aeration Influent Flow' (Annual Avg.)
NPDES Effluent Flow (Annual Avg.)
NPDES Effluent Flow (Max. Monthly Avg.)
Chemical Oxygen Demand (Annual Avg.)
Chemical Oxygen Demand (Annual Avg.)
Chemical Oxygen Demand (Max. Monthly Avg.)
MLSS2 (Annual Avg.)
MLVSS2(Annual Avg.)
MLVSS (Annual Avg.)
MLVSS (Max. Monthly Avg.)
MLVSS (Min. Monthly Avg.)
Temperature (Min/Max as Monthly Avg.)
Operating Parameters and Conditions
GPD
GPD
GPD
mg/L
Ibs/day
mg/L
mg/L
mg/L
Ibs
mg/L
mg/L
C
185,000
218,000
291,000
2,554
3,940
3,533
3,878
3,117
31,214
3,498
2,734
20/26.9
159,000
172,000
243,000
2,841
3,767
3,498
4,022
3,424
34,267
4,143
2,857
14.1/26.8
164,000
196,000
279,000
2,287
3,128
2,847
3,683
3,363
33,656
4,168
2,601
14.5/26.5
Aeration Basin TSS/VSS
F:M ratio (based on COD)3
SVI4
Recycle Ratio (Recycle/Influent)
Sludge Age (as an annual average)
Sludge Yield Actual
Sludge Yield Actual.
Solids Production (VSS Dry Basis)
Solids Production (TSS Dry Basis)
Effluent Performance
1.24
0.13
ml/g 317
6.9
days 75
Ib VSS/Ib COD 0.10
Ib TSS/Ib COD 0.12
Ibs VSS/day 402
lbs TSS/day 474
1.17
0.11
284
8.2
66
0.14
0.16
510
589
1.10
0.09
150
7.9
77
0.14
0.16
429
484
Clarifier TSS
COD
BOD
Ammonia
mg/L
mg/L
mg/L
mg/L
8.5
65
2.5
1.4
3.8
43
3.1
1.9
4.5
45
3.0
2.2
Notes;
1. Flow data measured at pH pit, does not include sanitary flow directly discharging into aeration basin, rainwater, other
2. MLVSS - Mixed liquor volatile suspended solids. MLSS - Mixed Liquor Suspended Solids
3. F:M ratio = Food to Microorganism ratio
4. SVI - Sludge Volume Index
5. Sludge yield is an estimated value, calculated based on annual averages
A review of the data indicates that the COD loading decreased from 2006 to 2008, which resulted
in a corresponding decrease in the F:M ratio (as the operating mixed liquor volatile
suspended solids (MLVSS) remained relatively constant). F:M ratio (along with sludge age) are
two critical parameters that characterize biological treatment systems and are used by DAK as
operational parameters.
Sludge settleability and compaction are measured using Sludge Volume Index (SVI) measured from
samples collected before the clarifier. Typically, a good settling sludge has a SVI of less than
80 to 100, and moderate settling sludge has a SVI in the range of 100 to 150. A poor settling
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ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
sludge is typically characterized by an SVI of greater than 150. As the data indicates, the
SVI values indicate poor to very poor settling sludge. As a result, DAK currently adds two organic
polymers KLARAID PC1224 and KLARAID IC1172P to enhance settling in the clarifier.
Both polymers are added at the effluent of the aeration basin.
As expected, a relative long sludge age is required due to the nature of the
organic chemical wastewater (longer sludge age is common for industrial wastewaters containing
slower degrading compounds), compared to the typical range where good settling biomass is
produced (typically on the order of 3 to 20 days).
From the operational data, sludge age was estimated as an annual average value, since wasting
does not occur every day. This value was estimated by summing the total annual volume wasted,
and calculating the total pounds wasted per year using the clarifier underflow volatile VSS
annual average concentration. Using this method, a sludge age of 65 to 75 days appears
necessary to provide an adequate treatment and MLVSS mass in the aeration basin.
The MLVSS data indicates that the aeration basin is operated with a MLVSS concentration in the
range of 2,600 to 4,200 mg/L.
The temperature data indicates that the aeration basin operates in the range of about 14 °C to
27 °C; however, the 14 °C condition occurred in the colder months when the pH pit steam flow was
turned off or at a reduced flow rate. It appears the temperature in the aeration basin could be
maintained at about 18 °C in the winter months with the steam flow operating in the range of
historical conditions.
Also, a review of the 2006 to 2008 data indicates the existing facility wastewater peak
monthly influent average temperature was 36.3 °C in August 2007; however this appears to be
relatively isolated event. Typically, the peak monthly average influent existing facility wastewater
temperature appears to be about 31 °C to 32 °C.
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Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
2.0 FLOW RATE ASSESSMENT
For the biological treatment assessment, based on information provided by CPR, three different
PET bottle recycle wastewater flow scenarios were considered:
• Phase I Start -Up of 2,000 kilogram per hour (kg/hour) production
• Phase I Production of 7,000 kg/hour production
• Future Phase II Production of12,000 kg/hour production
2.1 Phase I Start -Up Flow Rate
EnSafe understands that CPR initially plans to start-up production in spring 2010 operating with a
single 2,000 kg/hour production line that may not be continuous. The maximum Phase I start-up
bottle recycle wastewater flow rate assumes continuous operation and was estimated as follows:
2,000 kg/hour x 4.0 L/kg = 8,000 L/hour
8,000 L/hour x (7.4805 gallons/28.317 L) x 24 hour/day = 50,720 gallons/day
This is equal to about 35 gallons per minute (GPM) assuming continuous operation. CPR indicated
to EnSafe this value should be used as the initial flow.condition. Allocating 7,800 GPD for sanitary
and non -process wastewater the total estimated start-up flow rate assumed is 58,500 GPD.
2.2 Phase I Flow Rate
For the estimated bottle recycle wastewater flow, EnSafe was provided a Phase I projected
production capacity of approximately 120,000,000 lb/year (or approximately 7,000 kg/hour
assuming 90% process efficiency at 365 days per year). CPR provided EnSafe a
wastewater generation rate of 2 to 3 L wastewater per kg of product produced.
For estimating the daily average Phase I flow, EnSafe assumed an average daily value of
2.5 L wastewater/kg product plus a 10% safety factor. Using this approach, the following Phase I
flow rate was estimated:
7,000 kg/hr x 2.5 L/kg = 17,500 L/ hr
17,500 L/hour x (7.4805 gal/28.317 L) x 24 hr/day = 111,000 gal/day
111,000 gal/day x 1.10 (safety factor) = 122,100 gal/day
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ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
This flow rate was usedas the basis for simulated wastewater in our treatability study. A blended
feed was prepared at the aforementioned average flow conditions assuming 170,000 GPD of
existing wastewater and 122,100 GPD of bottle , recycle wastewater, or a total flow rate of
292,100 GPD. The percentages used were as follows:
Existing Wastewater Percentage = 170,000/292,100 = 58% (rounded to 60%for study)
Bottle Recycle Wastewater Percentage = 122,100/292,100 = 42% (rounded to 40% for study)
During the .course of the project, CPR revised the estimated wastewater generation rate and
indicated that a value of 4L/kg of product should be used for the pretreatment system design,
which includes all wastewater.
Therefore, for the Phase I condition, this change.resulted in a revised Phase I bottle recycle process
wastewater flow rate of 177,522 GPD.. Using this revised flow, plus other non -process wastewaters
at an average of,15 GPM (21,600) for city water (screen wash water and polymer make-up water)
used at the pretreatment system, .plus an estimated 1,800 GPD of sanitary sewage (see.
Pretreatment System Engineering Repot:0, the total estimated CPR. daily average discharge rate
estimated for the .Phase I condition is 201,000 GPD. .
Therefore, the combined daily average flow based on the 2006 to 2008 3-year average existing
daily flow plus the revised Phase I bottle recycle flow was assumed at 371,000 GPD. This results in
an expected average blended wastewater condition of about 51% CPR wastewater and
49% existing wastewater at average. Phase I conditions.
24 Future Phase II Flow Rate
EnSafe understands CPR plans to add another production line in the future, operating .. at
5,000 kg/hr, for a total of 12,000 kg/hour production capacity: Using this production rate and the
4 L/kg wastewater generation value, the Phase II flow rate was estimated as follows:
12,000 kg/hour x 4.0 L/kg = 48,000 L/hour
48,000 L/hour x (7.4805 gal/28:317 L) x 24 hour/day = 304,323 GPD
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ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
Allowing other pretreatment system non -process wastewaters at an average of 30 GPM
(43,200 GPD) for city water (screen wash water and polymer make-up water) used at the
pretreatment system, plus an estimated 1,800 GPD of sanitary sewage (see Pretreatment System
Engineering Report), the total estimated CPR discharge rate estimated for the Phase II condition is
347,600 GPM.
For the three bottle recycle wastewater flow conditions, the estimated daily average flow rate and
maximum monthly average flow are summarized in Table 5. The difference in the existing
daily average flow and maximum monthly average flow is due to storm water. EnSafe understands
that storm water that falls on various areas of the facility is collected and discharge to
wastewater treatment. The maximum monthly flow value reported in Table 5 was the
highest maximum monthly average flow rate observed from 2006 through 2008.
PET
Operational
Condition
Phase I Start -Up
Phase I
Phase II
Projected PET
Wastewater
Flow (GPD)
58,500
201,000
347,600
Table 5
Summary of Flow Conditions
2006-2008
Existing
Average Daily
Flow
(GPD)
170,000
170,000
170,000
2006-2008
Existing
Maximum
Month Average
Flow (GPD)
291,000
291,000
291,000
Projected
Average
Daily Flow
(GPD)
228,500
371,000
517,600
Projected
Maximum
Monthly
Average Flow
(GPD)
349,500
492,000
638,600
As discussed, in the recently issued NPDES permit, the permitted flow rate remains 0.500 MGD as a.
monthly average.
Based on this analysis, it would _appear there is a risk of exceeding the monthly average flow limit
during a large storm event for the Phase I condition. For the Phase II condition, the projected
daily average flow rate without the contribution of storm water exceeds the permitted flow limit.
Based on these flow projections, it would appear'a permit modification may be necessary for the
Phase II condition.
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£NSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
3.0 WASTEWATER SOURCES AND ANALYTICAL CHARACTERIZATION
The section provides a discussion of the wastewater source and analytical characteristics of the
existing facility wastewater and bottle recycle wastewater used for the treatability study.
Characteristics are also provided for the simulated bottle recycle pretreatment system effluent, at
two possible effluent TSS concentrations.
3.1 PET Bottle Recycle Wastewater Samples for Testing
EnSafe received four (4) approximately 100-Titer drums of PET bottle recycle wastewater provided
by CPR in mid -June 2009. The wastewater was collected from a PET Bottle Recycle facility located
in Italy' that uses the same process production technology proposed for the Cedar Creek facility.
EnSafe was informed to assume that this wastewater would be characteristic of the wastewater
generated at the proposed PET bottle recycle facility, and the non-ionic surfactant used in the
washing chemistry would be the same.
CPR provided EnSafe with information on the proposed alkaline washing chemical; Master RP10
supplied by MacDermid. EnSafe contacted MacDermid to obtain additional information for this
product. MacDermid indicated that the product. contains 5% to 10% potassium hydroxide,
approximately 7% phosphate, and 5% to 10% non-ionic surfactant. MacDermid was unable to
provide EnSafe additional information regarding the class or type of non-ionic surfactant used in
this formulation.
These four drums were placed in a walk-in cooler for storage at TestAmerica Laboratories, Inc.,
(TestAmerica) in Nashville, Tennessee, and labeled as Drum #1, Drum #2, Drum #3, and
Drum #4. EnSafe visually inspected two of the drums and assumed that the
wastewater characteristics were generally similar in each drum; however, during subsequent
biological treatability testing it became apparent Drum #4 was significantly different from the
other three, both in pH, color, and clarity. The. pH of Drum #4 was measured at 12.6, while the pH
of the other three drums was measured at 10.0. Also, this drum appeared to have Tess large
inert/plastic type solids, but a higher concentration of finer solids.
After noticing the difference, EnSafe informed CPR and a representative from the
aforementioned Italian facility indicated that the wastewater in the three similar containers was
collected at the same time, while the wastewater in the fourth was collected at a different time.
Also, it was indicated that the fourth drum may have been collected during a period when one of
the process tanks was being discharged (i.e., bled out), which results in an increase in pH.
13

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
The Italian facility indicated the most representative aliquot for testing would be an equal volume
composite of the four drums.
A sample of the untreated bottle recycle wastewater was submitted to TestAmerica on
June 16, 2009, for initial wastewater characterization. At the time of this initial sample collection,
the different characteristics of the drums were not known and this sample was obtained from one
of the three similar containers. Subsequently, an equal volume composite of the four drums was
submitted to Parkson Corporation (Parkson), The Andritz Group (Andritz), and TestAmerica for
solids analysis. Finally, after all testing was completed; an equal volume composite from the
four drums was re -submitted to TestAmerica for analysis. The results from these samples are
summarized in Table 6.
Table 6
PET Bottle Recycle Wastewater Characterization
Parameter
Drums
pH
Specific Gravity
Total Solids (TS) •
Total Suspended Solids (TSS)
Volatile Suspended Solids (VSS)
Total Dissolved Solids (TDS)
Chemical Oxygen Demand (COD)
Biological Oxygen Demand (BOD)
Total Kjedahl Nitrogen (TKN)
Ammonia Nitrogen
Total Phosphorus
Potassium
Sodium
MBAS Surfactants
June 17
TestAmerica
(mg IL)
July 8
Parkson
(mg/L)
Drums 1-3 Composite
9.9 12.38
1,7001
2,390
4,120
949
18.4
3.39
1.52
7,084
July 8
Andritz
(mg/L)
July 8
TestAmerica
(mg/L)
Composite Composite
12.5
1.0
15,200
2,800
4,540
Sept. 11
TestAmerica
(mg / L)
Composite
5,720
4,020
5,410
12.8
478
1,420
Note:
1. Test result re -reported by TestAmerica; however TSS value may be erroneous considering VSS result is
larger than TSS result
The sample results from the four composite samples indicated TSS results ranging from
2,800 to 7,084 mg/L (or 0.28% to 0.70% solids). Given the characteristics of the solids and the
TSS sampling and analysis procedure, some variability is expected in the analysis results.
Data from the September 11, 2009, TestAmerica sample indicated that the VSS fraction was
approximately 70% of the TSS, indicating a relatively high fraction of organic solids.
14

ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
3.2 Existing Facility Wastewater Samples for Testing
Approximately weekly during the treatability study, DAK personnel collected approximately 40 L of
influent wastewater from the pH pit. The influent wastewater was placed on ice in coolers and
shipped to EnSafe offices in Nashville. The existing facility wastewater was sampled for
various analytical parameters and routinely for total COD and soluble COD. The total COD and
soluble COD average data, and all other individual data are summarized in Table 7. For samples
where the CBOD and total COD was reported, the Total COD/CBOD ratio was calculated and the
CBOD estimated for the average total COD value.
Table 7
Existing Facility Wastewater Characterization
DAK Influent Wastewater)
Parameter (mg/L)
Total COD
Soluble COD
Total COD/CBOD Ratio
Estimated CBOD at Average Total COD
Total Phosphorus
Total Suspended Solids (TSS)
5,800
5,547
2.2
2,636
3.3
Total Dissolved Solids (TDS) 491
Total Solids
Total Kjedahl Nitrogen (TKN) 18.5
Ammonia Nitrogen 5.0
CTAS Surfactants
MBAS Surfactants 0.146
Notes:
1. DAK influent wastewater received on July 15, 2009, was significantly different from all other samples and
contained significant TSS. Total COD and soluble COD were reported at 6,660 and 685 mg/L,
respectively. This sample was not used for calculation of the average total and soluble COD averages.
The total COD measured in the existing facility wastewater was fairly consistent throughout
the study.
Of significance, the total COD of the existing facility wastewater measured from
June through July 2009 was essentially more than double the 2006 through 2008 annual average
COD (that ranged from 2,287 to 2,841 mg/L). Also, the total COD of the existing facility
wastewater measured from June to July 2009, exceeded the 2006 to 2008 peak monthly COD
(3,553 mg/L) by more than 60%.
15

ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
EnSafe reviewed the plant operation data provided. by •DAK for 2009, in particular for
June through August 2009, (i.e., .same period as treatability study). A summary of this data
comparedto the 2006 to 2008 long term average data is provided in Table 8.
Parameter
Table 8
Plant Operation Data Comparison
2006-2008
Long Term 'June August
Units Average 2009 July 2009 2009
Aeration Influent" Flow' GPD 170,000 173,000 163,000 ` 144,000
NPDES Effluent Flow GPD - 195,000 182;000 176,000 169,000
Chemical Oxygen Demand mg/L 2,560 6,489 5,606 . 3,885
Chemical Oxygen Demand Ibs/day 3,629 9.362 ' . 7,620 4,665
MLVSS2 mg/L 3,300 4,243 4,369 3,720
MLVSS Lbs '33,000 42,463 43,724 37,229
Estimated Sludge Age (monthly avg.) Days 73 — 47 51
F:M Ratio (based on COD) ' 0.11 0.22' 0.17 0.13
Effluent Performance
Clarifier TSS . mg/L • 5.6 5.0. 6.8 13
COD - rng/L 57 63 66 113
BOD - mg/L 2.9 7.9 4.9 . - 14'
Ammonia mg/L 1.8 1.1 7.1 ' 3.4
Based on information provided by DAK, the higher influent COD that began in June 2009 was due
to a unit process upset at the DAK facility, which resulted in a significant increase in the discharge
of ethylene glycol. .EnSafe understands .this',condition requires' a plant shutdown to repair;
therefore, • higher than normal COD loadings are expected to continue for some time. - -
Sludge was not wasted during the first several -weeks of June, resulting in the increases in the
MLVSS concentration in the aeration basin. Sludge was wasted on a daily basisthroughout
July 2009. As the data indicates, the effluent performance declined in response to this loading, in
particular for .BOD. .The effluent BOD increased from a long term- average of 2.9 mg/L to a range of
4.9 to 14.0 mg/L (July to August 2009 Average Effluent BOD 8.9 mg/L).
Although it was ;not desirable that the existing facility wastewater used during the course of the
treatability study coincided with a plant upset condition (which resulted in higher COD loading), it
does provide an indication as to the maximum COD loading and practical MLVSS maximum for the
1.2 MG aeration basin. .
`16

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
3.3 Simulated Pretreatment System Effluent
A complete discussion of the pretreatment regimes (for both fully pretreated and partially
pretreated wastewater) utilized to simulate pretreatment of the bottle recycle wastewater is
presented in the Pretreatment System Engineering Report, and summarized herein:
• Fully Pretreated: Screened using filter cloth, pH neutralized, coagulated using Nalco 8103,
flocculated using Nalco 7768, and solids separated. The TSS in the supernatant from this
treatment regime was very low (no settleable solids observed and wastewater clear).
• Partially Pretreated: Screened using filter cloth and pH neutralized. There was significant
TSS in the supernatant, simulating poor to low TSS removal by the fine solids
removal technology at the pretreatment system (estimated at 902 mg/L).
Representative samples of the bottle recycle wastewater treated to simulate the probable range
effluent characteristics of the pretreatment process were analytically characterized for
several parameters, including both conventional and non -conventional pollutants. This data is
summarized in Table 9.
Table 9
Existing Facility Wastewater Characterization
Parameter
Total COD
Soluble COD
Fully Pretreated Partially Pretreated
PET Wastewater PET Wastewater
(mg/L) (mg/L)
1,530 5,0451
1,580 1,480
Carbonaceous BOD5 (CBOD) 912
Total COD/CBOD ratio 1.67
Total Phosphorus
Total Suspended Solids (TSS)
Total Dissolved Solids (TDS)
Total Solids
9.1 —
Low 9022
4,840 5,5003
CTAS Surfactants
6,500
110 120
MBAS Surfactants
•
Notes;
1. Average of TestAmerica and Krofta results
2. Average of Krofta and Andritz results
3. Estimated by difference from the Andritz sample result; Total Solids = Total Suspended Solids + Total
Dissolved Solids
17

Parameter
ET SAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
Testing results for the partially treated bottle recycle wastewater with an estimated
TSS concentration of 902 mg/L indicated a total COD of 5,045 mg/L, compared to a soluble COD of
1,480 mg/L. By difference, this indicates a particulate COD of 3,565 mg/L and a COD/TSS ratio of
about3.9to 1.
The fully treated and partially treated bottle recycle wastewater wassampled for cobalt thiocyanate
reactive substances (CTAS), which provide an indication of the nonionic surfactant concentration.
Based on information provided by CPR, the surfactant proposed for use in the process is a
non-ionic type. Also, initial testing data on the untreated bottle recycle wastewater indicated for
Methylene Blue Active Substances (MBAS), which is a measure of anionic surfactant concentration,
indicated a value of 1.52 mg/L, suggesting the anionic surfactant concentration is relatively low.
The data for the fully treated and partially pretreated samples indicated a CTAS concentration of
110 to 120 mg/L.
EnSafe also sampled the fully pretreated sample for the following parameters: metals for which
there were permit limits (Method 200.7), volatile organic compounds (Method 624),
semi volatile organic compounds (Method 625), and cyanide (Method 335.4). All
volatile organic compounds and semi volatile organic compounds were not detected at the
reporting limit. The analytical results for cyanide and permit -limited metals are presented in
Table 10.
Table 10
Pretreated Wastewater Metals and Cyanide Results
Concentration
(mg/L)
Cyanide 0.0183
Chromium 0.00740
Copper 0.129
Lead 0.0222
Nickel 0:0485
Zinc 0.171
18

£NSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
4.0 BIOLOGICAL TREATABILITY STUDY
The objectives of the biological treatability study were the following:
• Estimate biological kinetic coefficients (based on soluble COD) for the blended wastewater
60% Existing Wastewater
— 40% Pretreated Bottle Recycle Wastewater
• Verify that a 70-day sludge age (historical plant operational condition) is adequate for the
blended wastestream
Verify that the slowly degrading organics in the existing facility wastewater are controlling
for biological degradation
Determine if the VSS discharged in the bottle recycle wastewater will be assimilated
and degraded
• Determine if aerobic biological treatment is likely to achieve the permit limits and if the
existing biological treatment infrastructure is adequate, based on the existing
aerobic activated sludge concept, to treat the combined flow
• Interpret the results from the treatability study and provide full-scale
operating recommendations
• Identify potential issues associated with the characteristics of the bottle recycle wastewater
and possible effects on the biological treatment system
• Identify system modifications and/or additional unit process steps that may be required
4.1 Materials and Methods
For the system set-up, DAK personnel collected and shipped approximately 80 L of treated
final effluent for use as dilution water for the treatability reactors. An aliquot of return activated
sludge (RAS) from the activated sludge system was collected and used as the initial microorganism
seed in the reactors.
19

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
For this treatability testing, EnSafe set-up and operated six approximately 10 to 20-Liter
continuous -feed biological reactors. The reactors contain an aeration chamber and clarification
chamber; a baffle separated the two chambers. The quiescent conditions in the clarification
chamber result in solids/liquid separation. The clarified effluent overflows the reactor into a
collection container and the solids are returned to the aeration chamber. Solids/liquid separation in
these bench -scale reactors is typically not as efficient an operating clarifier. Also, clarification
polymers were not used in this testing; however, clarification polymers are used by the facility (due
to the long sludge age and associated poor settling biomass) to achieve effluent limits. As a result,
higher effluent VSS concentrations were expected in the bench scale testing compared to actual
operational data.
The reactor testing scheme is summarized as follows:
• Control Reactor: Single Reactor (working volume 9.3 L)
- Existing Facility Wastewater
• Fully Pretreated: Four reactors at different sludge ages (working volume 19 L)
40%/60% blend of fully pretreated bottle recycle wastewater and existing facility
wastewater
• Partially Pretreated: Single Reactor (working volume 9.3 L)
— 40%/60% blend of partially pretreated bottle recycle wastewater and existing facility
wastewater •
The terms used in this report for each reactor are summarized as follows:
• Control Reactor: (Sludge Age = Fully Pretreated Sludge Age #3)
• Fully Pretreated: Sludge Age #1
• Fully Pretreated: Sludge Age #2
• Fully Pretreated: Sludge Age #3
• Fully Pretreated: Sludge Age #4
• Partially Pretreated: (Sludge Age = Fully Pretreated Sludge Age #3)
The reactors were continuously dosed using peristaltic laboratory scale feed pumps. The flow rate
to the reactors was selected to achieve an estimated hydraulic retention time of about 10 days
(based on estimated flow rates and presumption the 4.4 MG basin would be placed in service);
20

SAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
although actual hydraulic retention times varied during the course of the study due to
minor fluctuations in pumping rates.
The reactors were dosed from carboys. Blended feed solutions were prepared as necessary and
the feed carboys re -filled. Each week an untreated aliquot of bottle recycle wastewater stock was
treated (both fully and partially) and used as the source of simulated pretreatment system effluent.
The pH of boththe fully and partially pretreated bottle recycle wastewater was adjusted to 7.0.
Nitrogen and phosphorus were dosed directly to feed carboys to ensure the adequate nutrients
were present in the reactors. Air for both mixing the reactor contents and supplying oxygen to the,"
microorganisms was provided by a small compressor discharging through coarse bubble diffuser.
stones in the, bottom of each reactor.
For the initial acclimation period, the wastewater percentage wasincrementallyincreased over
6 days to achieve the 40%/60% blend (from June 16.to June 23). Given the difference in TDS
between the two wastewaters, EnSafe was concerned about shocking the organisms and elected to
ramp up the blend slowly. Initially all five reactors receiving the bottle recycle wastewater were fed
with partially pretreated wastewater, while coagulation/flocculation trials' were proceeding: After
the ramp, up to the 40%/60% -blend, the four reactors intended for testing the fully treated
bottle recycle wastewater were switched over from partially to fully pretreated bottle recycle
Wastewater on June 23..
The pH in each reactor was measured daily. The temperature of each reactor was maintained at
ambient conditions generally between approximately 20 °C and 21 °C. -Also, the dissolved oxygen,
in each reactor was measured daily to ensure a dissolved oxygen concentration of greater than
2.0 mg/L (assumed minimum value, below which substrate utilization rates ,may be reduced). The
oxygen uptake rate (OUR) was routinely measured. in each reactor by . collecting an
approximately 300 mi sample of mixed liquor in ,a BOD bottle and measuring the change in the
• dissolved oxygen, concentration over time.
During the course of the study, the reactor.MLVSS, the effluent VSS, and the effluent soluble.COD
were routinely measured. For, these parameters, samples were collected and submitted
to TestAmerica.
21

Biological System Assessment Report
�$n"DAKAmericas, LLE--
Fayetteville, North Carolina
November 2009
On June 23, sludge wasting began from the reactors .on.a volumetric basis. Each daysludge was
wasted at a constant volume and the change in reactor MLVSS .was tracked over time for an.
indication of steady state conditions:
The volume wasted from each reactor was different to achieve a different MLVSS concentration and
sludge age. A central objective of the study was to operate the Control Reactor, the
Partially -Pretreated reactor and one of the Fully Pretreated reactors (i.e., Fully Pretreated
Sludge Reactor #3) at the samesludge age, so that; direct comparisons could be made between
the reactors.
On July 13, due to generally decreasing reactor MLVSS concentrations in all reactors (with the;
exception of the fully pretreated reactor operating at the shortest sludge age, Fully Pretreated
Sludge Age #1), sludge wasting was ceased for.2 days. On July 15, sludge wasting was resumed.
at 50% of the original wasting rate in all reactors with the exception of the _Fully Pretreated
Sludge Age #1 reactor. Sludge wasting rates as a percentage of overall reactor volume are
summarized, in Table 11.
Reactor
Control Reactor
Table 11
Sludge Wasting Summary
Sludge Wasting
Percent of Reactor Volume
June 23-July 10
Sludge Wasting
Percent of Reactor Volume
July 10- End of Study
2.6% - 1.3%
Fully Pretreated: Sludge Age #1
Fully Pretreated: Sludge Age .#2
19% • .. 19%.
6.3% 3.1%
Fully Pretreated Sludge Age #3 3.1%
Fully Pretreated: Sludge Age #4
Partially Pretreated : - 2.6%
1.6%
1.9% 0.95%
1.3%
Charts of the MLVSS over time.for each reactor are provided in Appendix B. Based on a review of
the data at, the reduced sludge wasting rates; the MLVSS concentration in the Control Reactor,
Fully Pretreated Sludge Age. #3, ,Fully Pretreated Sludge Age #4, and the Partially Pretreated
Reactor appeared relatively stable after .7, to 8 days of operation; however, -the
MLVSS concentrations in the Fully Pretreated Sludge Age #1 and Fully Pretreated:Age #2 appeared
to be' slightly increasing, likely as a result of the higher growth rates occurring in these reactors.
For the purpose of this study, and considering the short tirneframe of the project, conditions .on
July 20 were assumed to be generally representative of steady state conditions. Therefore,
data collected from July 20 through July 27 (7 days) was used . for the purpose of this
biological„ assessment.
22.

ENSAFE
Biological System Assessment Report
DAKAmerits, LLC
Fayettevi//e,'North Carolina
November 2009
On July 27, after this testing was.. completed, the percentage ,of bottle recycle wastewater in the
feed was doubled from 40% to 80% for the . Fully Treated Sludge Age #3 and Fully Treated
Sludge Age #4 feed, to simulate a spike of bottle recycle wastewater. After-4 days ofreceiving this
dosing at the spike condition, the effluent was sampled for soluble COD and CBOD.
Additionally, the feed to the Fully Pretreated Sludge Age #2 reactor was ceased on July 27, and the
reactor was, aerated for 9 days in the absence of feed. A sample was collected from the reactor for
soluble COD analysis to determine the inert soluble COD, or the fraction of soluble COD that is
not biodegradable.
4.2 Data Summary
A complete summary of reactor operation- data for each reactor is provided in Appendix C. Data
from July 20 through July 27, which is assumed to generally represent the period of pseudo -steady .-
state operation, were used for this biological treatment assessment.
The July 20 to July 27, average values of the measured reactor variables (pH, dissolved oxygen,
and temperature) are presented in Table 12.
Reactor
Control Reactor
Fully Pretreated: Sludge Age.#1
Fully Pretreated: Sludge Age #2-
Fully Pretreated: Sludge Age #3
Fully Pretreated: Sludge Ag'e #4
Partially Pretreated
Table 12
Reactor Parameter Summary
pH
(s.u.)
6.62
8.13
8.05
7.90.
8.21,
8.22
Dissolved Oxygen
(mg/L)
6.4
6.7
6.1
4.8
7.4
6.8
Temperature
(°C)
21.0
20.8
20.7
20.6
20.2
19.8
Of note, the average' reactor pH for the Control Reactor was . measured . at a .value of 6.62,'
compared to 7.90 to 8.22 for the other reactors receiving the blended wastewater. This is due to
the low pH of the existing facility wastewater from m the presence of organic acids, . while the
bottlerecycle wastewater was adjusted to s 7.0 for the testing using sulfuric. acid. The
existing ,facility wastewater typically has a pH of 3.5 to 5:0prior to treatment.
The dissolvedoxygen was maintained well above 2.0 mg/L during the course of the study., .The '
dower dissolved oxygen value measured in the Fully Pretreated: Sludge Age #3 reactor was due to
the aeration supply tubing configuration.
23 •

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC.
Fayetteville, North Carolina
November 2009
For estimation of the reactor sludge age, the estimated mass of solids in the reactor, mass of solids
lost due to wasting and the mass of solids lost in the effluent were calculated.
The mass of solids lost due to wasting was estimated by summing the total reactor volume wasted
from July 20 through July 27, and using the average MLVSS to determine a total VSS mass wasted.
The mass of solids lost in the effluent was estimated by summing the total volume of
effluent measured in the effluent collection container from July 20 to July 27, and using the
average effluent VSS to calculate a total VSS mass lost in the effluent. The total mass of solids in
the reactors was estimated using the average MLVSS and the reactor volume. Using the approach,
the estimated sludge ages were calculated and are presented in Table 13.
Table 13
Estimated Reactor Sludge Ages
Estimated Sludge Age
Reactor (days)
Control Reactor
Fully Pretreated: Sludge Age #1
Fully Pretreated: Sludge Age #2
Fully Pretreated: Sludge Age #3
Fully Pretreated: Sludge Age #4
Partially Pretreated
65
4.3
30
71
89
68
As previously discussed, a central objective was to operate the Control Reactor, Fully Pretreated:
Sludge Age #3 Partially Pretreated Reactor at similar sludge ages so that direct comparisons
could be made. As the data indicates, the sludge age values for these three reactors were in
good agreement.
For the fully pretreated/existing facility wastewater and the partially pretreated/existing facility
wastewater blends, the influent average values for total COD, soluble COD and CBOD were
measured from samples collected directly out of the feed carboys.
For the existing facility wastewater, the average values reported are from weekly sampling of the
existing facility wastewater.
The July 20 to July 27 average values for total influent COD, soluble influent COD,
calculated influent particulate COD, and effluent soluble COD are presented in Table 14.
24

Biological System Assessment Report
DAK America4 LLC
Fayetteville, NorthCarolina
November 2009
Table 14
Reactor Analytical Data
Influent ' Influent
Average . Average
Total COD Soluble COD
Reactor . (mg/L) (mg/L)
. Control Reactor 5,800 '5,547
Fully Pretreated: Sludge Age #1 4,550 3,543
• Fully Pretreated'. Sludge Age #2 .4,550 . 3,543
. Fully Pretreated: Sludge Age #3 4,550 s 3;543
Fully Pretreated: Sludge Age #4 4,550 3,543
Partially Pretreated ' 7,235 ' 3,820
Influent
Average
Particulate
COD (mg/L)
253
1,007
1,007
1.007
1,007
3,415
Effluent
Average
Soluble
COD
(mg/L)
256
304
269 '
153
168
187•
Percent COD
Removal
95.5%
93.3%
94.0%
96.6%
96.6%
97.4%
To estimate the inert residual soluble COD, the Fully Pretreated: Sludge Age #2 reactor was
aerated in the absence of feed over 8 days. A sample that was collected'from the reactor indicated
an inert residua! soluble COD of 188 mg/L.
This value is slightly higher than the average effluent soluble COD observed in the Fully Pretreated:
Sludge Age #3 (153 mg/L) and Fully Pretreated: •Sludge Age #4 (168 mg/L) average
effluent values. Subtracting out residual inert soluble COD concentration for the observed
effluent average 'COD values, the COD removal was essentially complete in theFully. Pretreated:
Sludge Age #3 and Fully Pretreated: Sludge Age #4 reactors.
The July 2C,I to July 27 average values for influent CBOD,: effluent CBOD, reactor MLVSS, and
effluent VSS are presented in Table 15. -
Reactor -
Table 15
Reactor Analytical Data
Reactor
MLVSS
(mg/L)
Control Reactor 1,473
Fully Pretreated:.. Sludge Age e #1, - . 515
Fully Pretreated: Sludge Age #2 1,085
Fully Pretreated:. Sludge Age #3 1,950
.Fully Pretreated: Sludge Age #4 2;842
Partially Pretreated: • 2,073
Influent Effluent
Average Ayerage
Effluent VSS " . 'CBOD • CBOD Percent CBOD,
• (mg/L) (mg/L) (mg/L) •- Removal
51.5
204
.42.5
19.3
38
30
3,180
2,197
2,197
2,197
2,197
Note:
1. 5 mg/L is, used for CBOD data reported less than the detection limit of 20 mg/L
5.0 100%
119.3 94.50/0
70.8 96.7%
5.0 100°/0
36.8 - 98.3%
25

F SAF
Biological System AssessmentReport
DAK Americas, LLC
Fayetteville,.North Carolina
November 2009
The data from the Control,- Reactor indicated a CBOD Tess than. the detection limit, indicating
similar operating conditions compared .to the full . scale- system for treatment of .the existing
facility wastewater.
Data for. the Fully Pretreated: - Sludge Age. #2 reactor operating at a sludge age of 30 days
indicated an average 'CBOD of 70.8 mg/L, suggesting a sludge_ age of 30 days is not adequate to
achieve effluent limits. Data for the Fully Pretreated: Sludge Age #3 reactor operating at 70 days
indicated full treatment of.the CBOD, as indicated by effluent values Tess than the. detection limit
(20 mg/L). This suggests the fully pretreated, bottle recycle wastewater at 40% concentration did
not significantly impact the degradation rate of the existing facility wastewater organic material..
On July 24, the Fully Pretreated/Existing Facility:Wastewater feed tank was sampled directly for
CTAS nonionic surfactants and the, result indicated a value of 30 mg/L. Samples collected from the
effluent of the control reactor indicated a CTAS concentration of 19 mg/L. Samples collected from-:
the Fully Pretreated: Sludge Age #3 and .,Fully Pretreated: Sludge Age #4 indicated, -a
CTAS concentration of .19 mg/L and 11 mg/L, respectively. -
During thecourseof the study, a consistent significant foam layer characteristic of surfactant foam,
was observed in the Fully Pretreated: Sludge Age #1 and Fully Pretreated: Sludge Age #2
reactors. This surfactant type- foam was not observed in the Fully Pretreated:. Sludge Age #3 and -
Fully Pretreated #4 reactors, suggesting removal/degradation of the surfactant occurred.
The July 20 to July 27, average specific oxygen uptake rates and average measured SVI values
(from July 15 to July 28). are presented in Table 16:
Reactor -
Control Reactor
Fully Pretreated:- Sludge Age #1
;Fully Pretreated: Sludge Age #2
Fully Pretreated Sludge Age #3
Fully Pretreated: Sludge Age #4
Partially Pretreated -• •
Table 16
Reactor SOUR and SVI Data
Specific Oxygen Uptake Rate Average SVI
(mg Oxygen/mg VSS hr) (ml/g) -
0.0067. 177
0.0185 46
0.0098 - 102'
0.0048 231
0.0028 . - 318
0.0046 147
26

ENSAF
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
The data for the Control Reactor receiving only existing facility wastewater indicated an
average SVI of 177 ml/g, which is within the range of 2008 plant operational data. The
2006 annual average SVI was 317 ml/g and the 2007 annual average was 284 ml/g.
As the data indicates, the SVI for the four reactors receiving the fully pretreated/existing facility
wastewater blend increased with increasing sludge age.
The settling characteristics varied significantly in the three reactors operated at the same
sludge age; Control Reactor (SVI of 177 ml/g), Fully Pretreated: Sludge Age #3 (SVI of 231 ml/g)
and Partially Pretreated reactors (SVI of 147 ml/g). Of note, a few of the measured SVI values in
the Fully Pretreated: Sludge Age #3 reactor (operated at a sludge age of 70 days) exceeded
300 ml/g, although the average over this period was 231 ml/g.
In. general the settling characteristics observed in the Fully Pretreated: Sludge Age #3 and
Fully Pretreated: Sludge Age #4 reactors were worse than the Control Reactor. The settled sludge
was not as dense and tended to bulk upon agitation or turbulence. The specific characteristics of
the bottle recycle wastewater that resulted in a decrease in settling efficiency are not known;
however, it is speculated the increased TDS concentration may have been a factor.
Alternatively, as evidenced by the SVI, the sludge in the Partially Pretreated reactor receiving
TSS/VSS in the pretreated effluent settled very well, in fact better than the Control Reactor.
Based on visual observation, the settled sludge in this reactor was very compact and dense. It is
speculated the fine solids present in the bottle recycle wastewater act as a settling aid and improve
settling performance.
Therefore, these settling observations suggest that treatment of a very low solids effluent from the
bottle recycle plant is not desirable and the settling efficiency of the sludge may decrease
compared to current values, which could result in performance issues. Alternatively, the presence
of the bottle recycle solids appeared to act as a settling aid and.settling was enhanced.
4.3 PET Bottle Recycle Wastewater Slug
On July 27, the percentage of fully treated bottle recycle wastewater was increased to 80% (double
the 40%) to simulate a spike of bottle recycle wastewater. The 80% bottle recycle/20% fully
pretreated blend was dosed to the Fully Pretreated: Reactor #3 and Fully Pretreated: Reactor #3
for 4 days.
27

E IISAFE
Biological System Assessment Report
DAKAmericas, LLC
- Fayetteville, North Carolina
'November 2009
On July 31, the , effluent was sampled for soluble COD -'and CBOD. The results from the
Fully Pretreated: Reactor. #4 indicated results compared to the July 20 to July 27 operational data;
however, the results from the Fully Pretreated: Reactor #3 operated at a sludge age of 71 days
indicated a CBOD. 33.7 mg/L and a soluble COD of 157 mg/L. Although.the soluble COD was in
agreement with previous results, the'CBOD increased. -
:28

SAFE
Biological System Assessment Report
'DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
5.0 DETERMINATION OF BIOKINETIC COEFFICENTS
Aerobic, biological kinetic coefficients were determined for the 40% fullypretreated bottle recycle
wastewater 'and 60% existing facility wastewater .blend. . These coefficients were determined at"
ambient conditions in the laboratory at approximately 21, °C. Kinetic coefficients are a function of
the type of waste degraded and the type of microbial population established. The typical kinetic
coefficients that define the characteristics of a system are defined as follows:
IJmax = Maximum specific biomass growth rate coefficient (mg VSS/mg VSS, time, or 1/time)
Y = Yield. coefficient (mg new VSS/mg COD degraded)
K
Decay coefficient (mg VSS/mg VSS time, or 1 time)
Ks = Half saturation coefficient (mg COD/L)
- The approach used assumed the general completely mixed activated. sludge concept, assuming
steady state conditions and based on the following general. assumptions:
•
•
Complete mixing is achieved in the aeration basin
No biomass is contained in the influent
No microbial.activity in the secondary clarifier
No sludge;accumulates in the secondary clarifier
All biodegradable substrate is in the soluble form'
In existing facility wastewater, almost, all of, the total COD exists as soluble COD; therefore, the
aforementioned assumption that all :biodegradable substrate: is in .the soluble form is reasonable.
As previously discussed,'a significant fraction of the total COD 'in the bottle recycle wastewater may
be associated .with particulate COD (With the actual fraction, dependent on_ the performance of the
pretreatment system for TSS removal). However, based on ,a direct comparison of the performance
results between the partially pretreated/existing facility wastewater reactor (operating a sludge age
of 68. days) ' receiving particulate COD and the fully. pretreated/existing facility wastewater reactor
(operating a sludge -age .of 71 days) receiving low particulate COD, it can be inferred. the.
soluble COD is controlling.
29

Biological System Assessment ReportEllI
DAKAmericas, LLC
sn " Fayetteville, North Carolina
November 2009
Particulate organic matter (i.e.; particulate COD) must first be solubilized before it can, be. utilized as
substrate. These solubilizaiton reactions (i.e., hydrolysisreactions) are generally very. complex.
However, the reactor data suggests that the particulate COD was solubilized and biodegraded at
the long sludge age in the reactor. The average effluent VSS from July 15 to July 27, was 3,0 mg/L
in the partially pretreated/existing facility wastewater reactor, compared to 23.5 mg/L in the
fully pretreated/existing wastewater blend -reactor operated at the same sludge age, suggesting
there was little difference in effluent VSS. Also; the July 20 to July 27, average MLVSS in' the
partially pretreated/existing facility Wastewater reactor was measured at 2,150 mg/L, compared to
1,910 mg/L in the fully pretreated/existing wastewater blend reactor operated at the same sludge
age (Le., same wasting, rate), suggesting there was little difference in reactor VSS after weeks of
operation (i.e., no accumulation of non -biodegradable VSS). ,
On July 21, a single sample was analyzed for both TSS and VSS to assess the fraction of,
nonbiodegradable solids. The data indicated a TSS concentration. 'of 2,750 . mg/L. and a
VSS concentration of 2,200 mg/L, or- a TSS/VSS ratio of 1.25:1 in the reactor. Operational data ,
from 2006 to 2008 indicates an annual average TSS/VSS ratio in the aeration basin of 1.10 to 1.24.
For the purpose of this assessment, the 'substrate utilization rate of the soluble COD
(Le., presumed as the slow .degrading soluble organics in the existing facility, wastewater)
wasassumed to be controlling, rather than the solubilizaiton rate of the biodegradable solids.
The rate of substrate utilization was assumed to follow the Monod equation. The Monod equation
was simplified assuming first order kinetics. This is a, reasonable assumption when the steady state.
substrate concentration is less than the half -saturation constant, which is reasonable for system
'operating at long sludge ages. At long sludge ages, the direct determination of pmax and Ks is
difficult.. However, with a first order simplification, these :two parametersare combined into a
'single kinetic coefficient termed the specific substrate utilization rate constant ,(K), with units
of L/mg VSS, biomass hr.
A summary of the calculations to estimate the biokinetic coefficients is presented in 'Appendix D.
Additionally, oxygen use coefficients were estimated for the oxygen requirement calculations.
30

£NSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayettevi/le, North Carolina `
November 2009
Specific Substrate Utilization Rate Constant
To determine the specific substrate utilization rate constant (K), the general mass balance equation
for substrate (i.e:, COD) around the aeration basins was utilized assuming steady state conditions.
Atsteady state, 'the amount of substrate entering the aeration tank is equal to the amount of
substrate degraded or leaving the aeration tank (i.e., no net change of substrate). This
steady state mass balance equation was placed into -linear form and the first order simplification the
Monod equation was used for the substrate utilization term.
For the three fully treated bottle recycle wastewater/existing facility wastewater reactorsoperating
at sludge ages of 4.3, 30, and 71 days, the calculated specific substrate utilization .rate based on
soluble COD was plotted against the effluent readily biodegradable soluble COD concentration.
Since the effluent readily biodegradable soluble COD of the 71-day sludge reactor was assumed to
be zero (only the residual inert soluble COD fraction remains), an effluent readily biodegradable
soluble COD value of 5 mg/L was assumed for calculation purposes. The slope of a best fit linear
trendline was used to estimate the specific substrate utilization rate constant (K) for the
mixed wastewater.
Based on this approach, the specificsubstrate-utilization rate constant (K)" was estimated at a value
of 0.00012 L/mg hr (based on COD).. This substrate utilization rate constant is very low compared
to typical -values reported for domestic, wastewater of 0.00108 to 0.00137 L/mg hr (based on BOD);
however, it is reasonable agreement with literature reported values of 0.000050 to 0.000073 L/mg
hr for organic chemical wastewaters. (based on BOD).1
Yield Coefficient and Aerobic Decay Coefficient . -
To estimate the yield coefficient (Y) and the . aerobic decay coefficient (Kd), the general
mass balance equation for biomass around thesystem was utilized assuming steady- state
-.conditions. At steady state; the rate at which biomass is generated from growth is equal to the
rate at which biomass is lost due to decay plus the amount lost in the effluent (i.e., no net change
:in biomass concentration Iry the system). This steady state mass balance equation on the biomass
was: placed into - linear form and the -. standard . equation -relating biomass growth to
:substrate utilization and biomass decay to the biomass concentration - Was substituted for the
biomass term.
1 Biological Process Design For Wastewater Treatment, Benefield and Randall, 1985.
31

ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
For the three, fully treated bottle recycle wastewater/existing facility wastewater reactors operating
at sludge ages of,4.3, 30, and 71, days the calculated specific substrate utilization rate was plotted
against the reciprocal of sludge age. The slope and y-intercept from the best fit linear
trendline were used to estimate the yield coefficient (Y) and the aerobic decay coefficient (Kd) for
the mixed wastewater:
Based on this approach, the Yield Coefficient (Y) was estimated at 0.46 mg VSS biomass/mg COD
substrate. This is the range . of literature values . between 0.30 and 0.60; although this
estimated value is slightly higher than expected for the long sludge age required in this system.
By this 'method, the aerobic decay coefficient (Kd) wasestimated at a value of 0.077 per day. This
value is in the range of typical literature values of 0.048 per day to 0.24.per day; however, a
low decay coefficient is not unreasonable for this system.
Oxygen Use Coefficients
Oxygen use coefficients were estimated.by using a commonly.accepted linear form of the rate of
oxygen 'utilization equation'. These coefficients were determined by plotting the
specific oxygen utilization rate (SOUR) vs. the specific substrate utilization rate (q). The slope of
line represents the oxygen use coefficient A, Which is the oxygen use coefficient for synthesis. The
intercept of this Tine represents the oxygen coefficient B, which is the oxygen use coefficient of the
energy of maintenance.
Using the ,approach, the value for A was estimated at. 0.66 and the value for B was estimated at
0.0072 per day. Typical values for A in the literature range from 0.35 to 0.55. Of note, the
reactors were operated with a slight excess of nitrogen in the feed carboys, so the oxygen uptake
rates were likely influenced by nitrification which may explain the slightly higher -value of 0.66
.compared to literature values. These estimated values were used in ,the determination of the
oxygen requirement.
Goodman and Englande, 1975
32

NSA FE
Biological System Assessment Report
• DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
5.1 Temperature
An initial task. in the process is' to establish the maximum and minimum temperatures for
system assessment purposes. As discussed, the historical operation data indicates that the
current aeration basin operates in the range of about 14 °C to 27 °C, with a maximum reported''
monthly average value of 27.4 °C. During the colder months, steam is utilized at the pH pit to keep
the temperature above a minimum operating condition of about 14 °C.
The existing influent facility wastewater is warmer than ambient conditions. The 2006 to 2008
average influent wastewater temperature is about 29.7 °C (measured at the pH pit), with a,
2006 to 2008 maximum peak monthly average of 36.3 °C in August 2007. Of note, this
August 2007 value'is higher than other peak monthly average temperatures, and may be an
isolated event. Based on a review of the data,a maximum peak monthly temperature of about
33 °C appears to be more representative. As a result, both conditions were utilized in
this assessment.
A review of the data during the warmer months (where no steam is utilized) at the current flow
conditions, indicates that on average about 5°C of cooling occurs in the existing 1.2 MG aeration
basin, as a result of both environmental conditions, residence time, other waters, and the cooling
effect of the aerators.
Based on discussions with CPR, EnSafe was provided an ,estimated pretreated effluent temperature
at the time of discharge to the existing equalization tanks of 45 °C.
For- the purpose ,of this assessment, based on ,.the historical , operational data, cooling in the
aeration basin, and estimated bottle recycle wastewater temperature, the- minimum and maximum
aeration basin temperatures selected for' evaluation are:
Minimum Temperature: 18 to 20 °C (Based' on minimum from historical operational data at
14 °C-to 18 °C, plus temperature rise expected from bottle recycle wastewater).
Considering the minimum deign temperature in the basin was 18 °C to 20 °C, the specific
substrate utilization rate. constant - and the aerobic decay coefficient were not adjusted to
temperatures lower than; the laboratory condition.
Maximum Temperature: 35 °C (Based on assumed increase from bottle recycle wastewater)
33

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
The maximum operating temperature considered was based on the maximum typical
operating activated sludge temperature of 35 °C for mesophillic organisms. Above 35 °C the
biomass growth rate growth may be inhibited and treatment performance affected; therefore, 35 °C
is considered a practical maximum and an operational limit.
The loss of heat in Aeration Basin #1 (4.4 MGD) is assumed to be greater than that occurring in'
Aeration Basin #2 (1.2 MGD) due to the larger surface area, different type aerators, and longer
residence time. Therefore, at a bottle recycle wastewater temperature of 45 °C, it was assumed
there is more of a concern for temperature effects operating in Aeration Basin #2. A detailed
assessment of heat loss in Aeration Basin #2 was beyond the scope of this study.
Using the existing system operational data, projected bottle recycle wastewater temperature of
45°C (assumed at discharge to existing facility equalization tanks), and 2006 to 2008 maximum
peak monthly average temperature of 36.3 °C, the influent temperature was estimated as a flow
weighted average, assuming no heat loss in the existing equalization tanks. In later section of this
report, it was concluded that for the Phase II flow, the existing 1.2 MG basin is not adequate;
therefore, the estimated influent temperature for the Phase II condition was not estimated.
The estimated influent temperature for the Phase I Start -Up condition and the Phase I full scale
operation is presented in Table 17.
PET
Operational
Condition
Phase I Start -Up
Phase I
Projected PET
Wastewater
Flow (GPD)
58,500
201,000
Table 17
Estimated Influent Temperature
Peak Monthly Average of 36.3°C
2006-2008
Existing
Average Daily
Flow
(GPD)
170,000
170,000
Assumed PET
Wastewater
Temperature
(Degrees C)
45
45
2006 to
2008 Peak
Monthly
Average
Temperature
(Degrees C)
36.3
36.3
Projected Flow
Weighted
Average
Influent
Temperature
(Degrees C)
38.5
41
As indicated, for the 2006 to 2008 operational data, it appears that about 5 °C cooling occurs in the
aeration basin on average at the 2006 to 2008 average flow rate of 170,000 GPD.
34

SAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
It is difficult to estimate the change in heat loss as the flow increases in Aeration Basin #2 due to
multiple factors. However, using a simplistic approach based on the ratio of hydraulic residence
time for the existing condition to the Phase I Start-upand full Phase I conditions, the estimated
corresponding temperature decrease in Aeration Basin #2 can be estimated.
Using this method, for the Phase I start-up condition, a temperature decrease of 3.6 °C was
estimated, which results in a projected peak monthly average temperature in Aeration Basin #2 of
34.9 °C. For the full Phase I condition, a temperature decrease of 2.3 °C was estimated, which
results in a peak monthly average temperature in Aeration Basin #2 of 38.7 °C.
Obviously, this calculation indicates there is risk of exceeding the maximum operating temperature
of 35. °C in Aeration Basin #2, assuming a peak monthly average existing facility wastewater
temperature of 36.3 °C and a bottle recycle wastewater temperature of 45 °C.
Using a 33 °C peak monthly average for the existing facility wastewater, the estimated aeration
basin temperatures were re -calculated and the results are presented in Table 18.
PET
Operational
Condition
Phase I Start -Up
Phase I
Projected PET
Wastewater
Flow (GPD)
58,500
201,000
Table 18
Estimated Influent Temperature
Peak Monthly Average of 33 °C
2006-2008
Existing
Average Daily
Flow
(GPD)
170,000
170,000
Assumed PET
Wastewater
Temperature
(Degrees C)
45
45
2006 to
2008 Peak
Monthly
Average
Temperature
(Degrees C)
33
33
Projected Flow
Weighted
Average
Influent
Temperature
(Degrees C)
36.1
39.5
Using the same temperature deceases as previously estimated; for the Phase I start up condition
an estimated peak monthly average temperature of 32.5 °C was estimated for Aeration Basin #2.
For the full scale Phase I condition, the estimated aeration basin temperature is 37.2 °C
In summary, this analysis indicates that for the Phase I start-up condition using Aeration Basin #2,
the maximum allowable aeration basin temperature of 35 °C should not be exceeded, so long as
the bottle recycle wastewater temperature is Tess than 45 °C at the discharge to the existing
equalization tanks.
35

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
For the full Phase I operating condition, using Aeration Basin #2, this analysis indicates the
maximum allowable aeration basin temperature of 35 °C would be exceeded at the existing
facility wastewater peak maximum monthly average temperature of 33 °C to 36.3 °C, assuming a
bottle recycle wastewater temperature of 4 5°C at the discharge to the existing equalization tanks.
Based solely on temperature; this analysis indicates that for the full scale Phase I condition,
operation in Aeration Basin #1 would be required, or operation in Aeration Basin #1 with
additional cooling provided in Aeration Basin #2, or cooling of the bottle recycle wastewater.
36

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
- Fayetteville, North Carolina
November 2009
6.0 BIOLOGICAL TREATABILITY, ASSESSMENT
The first step in assessing the system is to select/determine the target operating sludge age. Using
the sludge age, the following operational parameters were estimated for the design cases selected:
• Projected Aeration Basin VSS .concentration
• Oxygen Requirement
• Aeration Supply Capacity
• Solids Generation Rate
6.1 Selected Sludge Age
Based on the reactor data obtained from the reactor operating ata 70 day sludge age, this value
was selected for biological system assessment. -
Data from the 70-day sludge age reactor receiving the fully pretreated/existing facility wastewater
blend indicated'a readily biodegradable soluble COD effectively near or at zero and an effluent
CBOD of Tess than the'detection limit.
6.2 . Design Cases Evaluated
For the existing facility wastewater, based on the information provided; two COD loading scenarios
were utilized for, analysis at the current facility average flow of 170,000 GPD:
-Historical Average Loading: Total COD 2,560 mg/L (2006 to 2008 average)
Upset Condition Loading: Total COD 5,800 mg/L (June/July 2009 Upset Condition)
EnSafe was not, provided information on the timing for the unit process operation repair, which
would be assumed to restore the COD to within historical ranges, or if this type of upset condition,
may re -occur in the future.
For the bottle recycle pretreated wastewater, a best case and worst case condition was assumed
with respect to ,the expected particulate COD in the effluent. As indicated in the
Pretreatment System, Design Report, based on the coagulation/flocculation chemistry used and the'.
efficiency of the centrifuge as a function of wastewater conditions, the estimated TSS in the bottle
recycle pretreated effluent is between-100 and 600 mg/L.
37,

£NSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
For this analysis, the worst case bottle recycle wastewater condition was assumed at a TSS of
900 mg/L, with essentially all the TSS assumed as VSS (or otherwise is biodegradable and exerts an
oxygen demand). The best case condition was assumed at the 100 mg/L optimum condition
previously projected. These two bottle recycle wastewater effluent cases are summarized
as follows:
• Worst Case: Total COD 5,000 mg/L (1,500 mg/L soluble COD, 3,500 mg/L particulate COD)
• Best Case: Total COD 1,890 mg/L (1,500 mg/L soluble COD, 390 mg/L particulate COD)
As discussed, it appears the slow degradation of the organics in the existing facility wastewater is
controlling; therefore, operating at a sludge age of 70 days, the particulate fraction was assumed
as soluble COD.
6.3 Projected MLVSS Concentration
The 1,890 to 5,000 mg/L bottle recycle wastewater COD projected range was utilized for this
analysis, assuming the June/July 2009 existing facility wastewater COD concentration and that the
existing facility wastewater COD concentration is restored to historical values.
The MLVSS concentration was estimated for the three flow scenarios previously presented. A
review of the results, compared to actual plant operating data,.indicate these approximations may
tend to understate the actual VSS, which could be higher.
Based on general activated sludge operation, in order to develop a biomass that will settle well in a
secondary clarifier, a MLSS (based on TSS) concentration should be maintained between
2,000 mg/L and 5,000 mg/L.3. If the MLSS value is too low, a flocculent biomass will not develop
properly and the sludge will settle poorly. Also, a sufficient concentration of MLSS is needed for
adsorption/entrapment of particulate matter (i.e., particulate COD) contained in the influent. If the
MLSS concentration is low, adsorption/entrapment will be low and overall removal performance will
be poor. For removal of particulate COD, it is more desirable to operate at the higher end of the
operational MLSS range.
3 Biological Wastewater Treatment, Grady et. Al, 1999
38

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
For this assessment, the maximum MLSS concentration was assumed to be controlled by the
allowable solids loading rate of the existing clarifier. For SVI values of 300 ml/g, the EPA Manual
for Suspended So/ids Remova/ indicates a design solids loading value of 10 Ibs/day ft2. This value
was used in this assessment to predict maximum MLVSS concentrations (See Section 6.7).
For this analysis,; based on both literature information and actual plant operation data, 1,000 mg/L
to about 4,000 mg/L was used asa range of reasonable operating MLVSS concentration at the
design sludge age of 70 days.
Based on the atypical COD loading observed at the facility since June 2009, and a review of the
operational data, it would appear approximately 4,000 to 4,300 mg/L VSS represents a
possible maximum above which there is a higher'risk of effluent quality deterioration.
Case A; Upset COD Loading, Existing Facility Wastewater at Total COD = 5,800 mg/L
Two cases- were evaluated at the expected range. of performance for the PET pretreatment plant,
assuming the June/July 2009 existing facility wastewater COD loading:
• Case Al: PET Wastewater Total COD of 5,000 mg/L
• Case A2: PET Wastewater Total COD of 1,890 mg/L
For the three flow scenarios assumed (Phase I Start -Up, Phase I, and Phase II); the estimated .
MLVSS concentration in. the 1.2 MG and 4.4 MG aeration basin are summarized in Table 19-for
Case Al and Table 20 for Case A2. VSS concentrations outside of the assumed reasonable range of
1,000 to 4,000 mg/L range are italicized and noted in boldface font. -
Table 19
Case Al: Estimated Aeration Basin VSS Concentrations
Existing Facility Wastewater COD 5,800 mg/L, PET Wastewater COD 5,000 mg/L
PET Operational
Condition
Phase I Start -Up
Phase I
Phase II
Projected
PET Flow
(GPD)
58,500
201,000
347,600
Existing
Average
Daily
Flow
(GPD)
170,000
170,000
170,000
Total
Daily
Average
Flow
(GPD)
228,500
371,000
517,600
1.2 MG
Total Aeration
COD Basin
Loading Estimated
(lbs/day) . VSS (mg/L)
10,337 5,195
15,625 7,852
20,900 10,502
4.4 MG
Aeration
Basin
Estimated
VSS (mg/L)
1,417
2,141
2,864
39.,

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
Table 20
Case A2: Estimated Aeration Basin VSS Concentrations
Existing Facility Wastewater COD 5,800 mg/L, PET Wastewater COD 1,890 mg/L
Existing Total
Average Daily Total
Projected Daily Average COD
PET Operational PET Flow Flow Flow Loading
Condition (GPD) (GPD) (GPD) (Ibs/day)
Phase I Start -Up 58,500 170,000 228,500 9,022
Phase I 201,000 170,000 371,000 11,021
Phase II 347,600 170,000 517,600 13,015
1.2 MG
Aeration
Basin
Estimated
VSS (mg/L)
4,533
5,534
6,531
4.4 MG
Aeration
Basin
Estimated
VSS (mg/L)
1,236
1,509
1,781
The assessment indicates that if the existing facility wastewater influent COD remains at the
5,800 mg/L condition experienced in June and July 2009 (or occurs in the future); the existing
1.2 MG basin does not appear to have sufficient volumetric capacity to handle the total projected
increased COD load from the bottle recycle wastewater at the Phase I start-up condition.
For Case A, operation of the 4.4 MG gallon aeration basin is required.
Case B: Historical COD, Existing Facility Wastewater at Total COD = 2,560 mg/L
Two cases were evaluated at the expected range of performance for the PET pretreatment plant,
assuming the historical average COD loading for the existing facility wastewater:
• Case Bi: PET Total COD of 5,000 mg/L
• Case B2: PET Total COD of 1,890 mg/L
For the three flow scenarios assumed (Phase I Start -Up, Phase I, and Phase II); the estimated
MLVSS.concentrations in the 1.2 MG and 4.4 MG aeration basin are summarized in Table 21 and
Table 22, for Case B1 and Case B2, respectively. VSS concentrations outside of the assumed
reasonable range of 1,000 to 4,000 mg/L range are italicized and noted in boldface font.
Based a review of actual plant operating data, it would appear the calculation methodology for
estimating projected VSS concentrations may underestimate the actual VSS concentrations by at
least 700 mg/L. Therefore, adjusted values of VSS (assuming 700 mg/L VSS
additional concentration) are shown in parenthesis in the Table 21 and Table 22 for comparison.
40

r
EJVSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
Table 21
Case B1: Estimated Aeration Basin VSS Concentrations
Existing Facility Wastewater COD 2,560 mg/L, PET Wastewater COD 5,000 mg/L
PET Operational
Condition
Phase I Start -Up
Phase I
Phase II
Total
Existing Daily Total
Projected Average Average COD
PET Flow Daily Flow Flow Loading
(GPD) (GPD) (GPD) (Ibs/day)
58,500 170,000 228,500 5,744
201,000 170,000 371,000 11,031
347,600 170,000 517,600 16,306
1.2 MG
Aeration
Basin
Estimated VSS
(mg / L)
2,882 (3,582)
5,539 (6,239)
8,189 (8,889)
4.4 MG
Aeration
Basin
Estimated
VSS (mg/L)
786 (1,486)
1,511 (2,211)
2,233 (2,933)
Table 22
Case B2: Estimated Aeration Basin VSS Concentrations
Existing Facility Wastewater COD 2,560 mg/L, PET Wastewater COD 1,890 mg/L
Existing Total
Average Daily Total
Projected Daily Average COD
PET Operational PET Flow Flow Flow Loading
Condition (GPD) (GPD) (GPD) (lbs/day)
Phase I Start -Up
Phase I
Phase II
58,500 170,000 228,500 4,429
201,000 170,000 371,000 6,427
347,600 170,000 517,600 8,421
1.2 MG Aeration
Basin Estimated
VSS (mg/L)
2,220 (2,920)
3,221 (3,921)
4,219 (4,919)
4.4 MG
Aeration
Basin
Estimated
VSS (mg/L)
606 (1,306)
878 (1,578)
1,151 (1,851)
Assuming an existing facility wastewater COD of 2,560 mg/L, this analysis indicates that the
existing 1.2 MG aeration basin has adequate capacity for .the increased COD loading from the
Phase I Start -Up condition, for both the minimum and maximum range of COD concentration evaluated.
For the full Phase I flow condition, it is less certain that the 1.2 MG basin has adequate capacity,
and this outcome will be sensitive to the performance of the CPR pretreatment plant.
It appears that if the CPR pretreatment plant operated at optimum conditions, producing an
estimated effluent total COD concentration of 1,890 mg/L or Tess, the 1.2 MG basin will under
normal conditions be sufficient; however, there would be marginal capacity for peak Toads due to
upset conditions or other situations resulting in increases in the COD loading. If, on the other
hand, the CPR pretreatment plant operated at a condition .producing an estimated effluent
total COD.concentration of 5,000 mg/L, the 1.2 MG basin would not be adequate, and the 4.4 MG
basin would be required.
For the Phase II condition, the 4.4 MG aeration basin is required.
41

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November2009
Of note, during the Phase I start-up condition and full Phase I condition, the projected
VSS concentration in the 4.4 MG basin may be below the generally acceptable range, assuming the
historical COD loading for the existing facility wastewater and the best case conditions for the
bottle recycle wastewater. This may be of particular concern during the Phase I start-up condition.
6.4 Oxygen Requirement
As discussed in previous sections of the report, oxygen uptake measurements were made
frequently during the treatability study. Evaluation of the data shows that the oxygen required can
be estimated by the following oxygen rate equation:
AOR = (A x COD) + (B x MLVSS)
Where:
AOR is the actual oxygen required, Ibs/day
COD is the COD removed, Ibs/day
MLVSS is the mass of VSS in the system, Ibs.
As discussed, calculations based on treatability study data show A = 0.66 Ibs oxygen/lb COD and
B = 0.0072 Ibs oxygen/Ib MLVSS day. Oxygen requirements were estimated for each of the
scenarios previously presented are presented in the following tables.
Case A: Upset COD Loading, Existing Facility Wastewater at Total COD = 5,800 mg/L
For the three flow scenarios assumed (Phase I Start -Up, Phase I, and Phase II) and the estimated
MLVSS concentrations in the 1.2 MG and 4.4 MG aeration basins, the projected
oxygen requirements are summarized in Table 23 for Case Al and Table 24 for Case A2.
Table 23
Case Al: Oxygen Requirements
Existing Facility Wastewater COD 5,800 mg/L, PET Wastewater COD 5,000 mg/L
1.2 MG Aeration Basin 4.4 MG Aeration Basin
Estimated Estimated
Total COD Oxygen Oxygen
PET Operational Loading Estimated Required Estimated Required
Condition (Ibs/day) VSS (Ibs) (Ibs/day) VSS (Ibs) (Ibs/day)
Phase I Start -Up 10,337 82,300 7,420 60,300 7,260
Phase I 15,625 124,000 11,210 91,000 10,970
Phase II 20,900 166,000 14,990 122,000 14,670
42

Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
Table 24
Case A2: Oxygen Requirements
Existing Facility Wastewater COD 5,800 mg/L, PET Wastewater COD 1,890 mg/L
PET Operational
Condition
Phase I Start -Up
Phase I
Phase II
Total COD
Loading
(lbs/day)
9,020
11,020
13,020
1.2 MG Aeration Basin 4.4 MG Aeration Basin
Estimated
VSS (Ibs)
71,800
87,700
103,000
Estimated
Oxygen
Required
(lbs/day)
6,470
7,910
9.330
Estimated
VSS (lbs)
52,600
64,200
75,800
Estimated
Oxygen
Required
(Ibs/day)
6,330
7,740
9,140
Case B: Historical COD, Existing Facility Wastewater at Total COD . 2,560 mg/L
For the three flow scenarios assumed (Phase I Start -Up, Phase I, and Phase II) and the estimated
MLVSS concentrations in the 1.2 MG and 4.4 MG aeration basin, the projected oxygen requirements
are summarized in Table 25 for Case B1 and Table 26 for Case B2.
Table 25
Case B1: Oxygen Requirements
Existing Facility Wastewater COD 2,560 mg/L, PET Wastewater COD 5,000 mg/L
PET Operational
Condition
Phase I Start -Up
Phase I
Phase II
Total COD
Loading
(Ibs/day)
5,740
11,030
16,040
1.2 MG Aeration Basin 4.4 MG Aeration Basin
Estimated
VSS (Ibs)
45,700
87,800
130,000
Estimated
Oxygen
Required
(Ibs/day)
4,120
7,910
11,520
Estimated
VSS (lbs)
33,400
64,300
95,000
Estimated
Oxygen
Required
(Ibs/day)
4,030
7,740
11,270
Table 26
Case B2: Oxygen Requirements
Existing Facility Wastewater COD 2,560 mg/L, PET Wastewater COD 1,890 mg/L
1.2 MG Aeration Basin 4.4 MG Aeration Basin
PET Operational
Condition
Phase I Start -Up
Phase I
Phase II
Total COD
Loading
(Ibs/day)
4,430
6,430
8,420
Estimated
VSS (Ibs)
35,200
51,000
66,900
Estimated
Oxygen
Required
(Ibs/day)
3,180
4,610
6,040
Estimated
VSS (Ibs)
25,800
37,300
49,000
Estimated
Oxygen
Required
(Ibs/day)
3,110
4,510
5,910
43

SAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November2009
6.5 Existing Aeration Capacity Assessment
The existing 1.2-million-gallon aeration basin is equipped with seven surface aerators, having a
combined nameplate rating of 405 HP. Five are fixed -platform -mounted, low speed aerators, of
which two are 50 HP, two are 40 HP, and one is a 75 HP unit. This type of aerator functions by
throwing water laterally and slightly upward through the air. The other two units are
75-HP Aire-02 floating aerators, which utilize a blower and a submerged mixer to inject air below
the water surface. Historically, DAK has utilized from three to five of the fixed aerators for
normal operations, and has used the floating aerators for supplemental air during periods of
heavy loading.
The idle 4.4 MG aeration basin has one 75-HP and five 150-HP Aqua-Lator floating surface aerators,
and one 75-HP Aire-02 floating aerator, for a total installed aeration capacity of 900 HP.
To assess the oxygenation capacity of this equipment, EnSafe reviewed DAK operating records over
the period of January 2007 through May 2008, during which only the 1.2-million-gallon aeration
basin has been in operation. In particular, the monthly average values for oxygen uptake rate
(OUR), dissolved oxygen (DO), temperature (T), and operating horsepower were extracted from
the records and compiled. In an operating aeration basin, the oxygen supplied by aerators satisfies
the OUR and any excess oxygen raises the DO of the mixed liquor. Although, both OUR and DO
may vary from hour to hour in response to fluctuations in wastewater loading, over a period of time
the average OUR, when adjusted for DO and temperature, can be used to estimate the capacity of
operating aeration equipment.
The data during this period reveals that the existing aerators, in particular the fixed -platform
aerators, have an apparent actual oxygen transfer efficiency (AAOR) of approximately 0.4 pounds
of oxygen per horsepower -hour (Ibs 02/hp-hr). When adjusted for differences in dissolved oxygen
and corrected to 20 °C, the actual oxygen transfer efficiency is also 0.4 Ib 02/hp-hr. Low -speed
surface aerators of this type typically have standard oxygen transfer efficiencies (SOR, measured at
20 °C and one atmosphere pressure in clean water) on the order of 1.5 to 2.0 Ib 02/hp-hr. The
lower AAOR implies that characteristics of the DAK wastewater are interfering with oxygen transfer,
likelyby. reducing the saturated dissolved . oxygen..concentration in the mixed liquor at a given
temperature (commonly referred to as the beta effect) and by interfering with molecular transfer at
the air -water interface (referred to as the alpha effect). These factors are particular to a
specific wastewater and are not correctable. Their combined apparent effect in the existing facility
wastewater is to reduce transfer efficiency to between 0.2 and 0.26 of that expected in clean water
at standard conditions. This is an unusually large effect and suggests that other factors may
be involved.
44

Biological System Assessment Report
- EJ1ISAFE
DA, North Americas, LLC
Fayetteville, North Carr olina
November2009
Other factors potentially reducing oxygen transfer capacity, which are correctable, include that the
fixed platform aerators might be set such that their impellers are slightly higher than their design
elevation relative to the water surface in the aeration basin or that the impellers are worn.
Assuming for now that the physical positioning and condition of the aerators will remain
unchanged, the actual oxygen transfer efficiency is estimated to be approximately 0.56 Ib 02/hp-hr
at the anticipated aeration basin operating temperature of 35 °C.
Based on analysis and information provided by CPR, the bottle recycle wastewater is known to have
higher TDS and expected higher surfactant concentrations than the existing facility wastewater.
These two parameters tend to decrease alpha (surfactants) and beta (TDS). The extent of these
effects cannot be easily calculated, so for purposes of this evaluation the estimated transfer
efficiency of the existing aeration equipment has been assumed to be further discounted to
0.5 Ib 02/hp-hr.
Inferred Alpha Factor
Using a commonly accepted relationship for Beta (a)4 and assuming a total dissolved solids
concentration of 2,500 mg/L, R was estimated at a value of 0.98. This value is reasonable, based
on several references which cite values of f3 in the range of 0.94 to 0.95 for wastewaters at
10,000 mg/L total dissolved solids.
Using the following equation for mechanical surface aerators5 an alpha value was inferred assuming
a minimum dissolved oxygen concentration of 2.0 mg/L and a basin temperature of 35 °C.
AOR = a(SOR) /3C C— C° (BT-2o )
s
AOR = Actual oxygen transfer rate at field conditions (lbs 02 per day), discounted value of
0.50 02/hp-hr assumed.
SOR = Standard clean water oxygen transfer rate at 20 °C and 1 atm (lbs 02 per day), typically
provided by vendor, assumed as 2.0 lbs 02/hp-hr
4 Biological Process Design for Wastewater Treatment, Benefield and Randall, 1985
5 Manual of Practice 8, Wastewater Treatment Plant Design, 1977
45

ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
Alpha = ratio of oxygen transfer in wastewater relative to clean water, dimensionless
= oxygen saturation value of clean water at site conditions, assumed at 35 °C as 6.93 mg/L
Co = Basin steady state dissolved oxygen level, assumed at 2.0 mg/L
CS = oxygen saturation value of clean water at standard conditions of 20°C and 1 atm, assumed as
9.07 mg/L
0 = temperature correction constant = 1.024
Based on the previous equation, the inferred alpha value is calculated as follows:
0.501bs02 — a 2.01bsO2.\ (0.98X6.93) — (2.0))!
1.024"-2°)
hphr hphr 9.07
Inferred Alpha = 0.33
Using the 0.5 Ib 02/hp-hr value for the actual oxygen transfer efficiency value, the projected
aeration capacity of existing aerators is:
405 Hp x 0.5 x 24 = 4,860 Ib 02/day in the 1.2-million-gallon
900 Hp x 0.5 X 24 = 10,800 Ib 02/day in the 4.4-million-gallon basin.
(Note: while the Aire-02 type aerators tend to have a higher SOR than the low -speed surface type
due to finer bubble size, smaller bubbles are more adversely affected by alpha effects; therefore,
the AAOR of these units is assumed to be comparable to that of the low -speed surface aerators in
this application.) A summary of these calculations is provided in Appendix E.
For the three flow scenarios assumed (Phase I Start -Up, Phase I, and Phase II) and the estimated
MLVSS concentrations in the 1.2 MG and 4.4 MG aeration basin, the projected aeration
requirements are summarized in Tables 27 through 30. Aeration requirements exceeding the
output of the existing equipment are noted in boldface font.
46

ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
Case A: Upset COD Loading, Existing Facility Wastewater at Total COD = 5,800 mg/L
Table 27
Case Al: Aeration Capacity Assessment
Existing Facility Wastewater COD 5,800 mg/L, PET Wastewater COD 5,000 mg/L
1.2 MG Aeration Basin 4.4 MG Aeration Basin
Estimated Estimated Estimated Estimated
Oxygen Aeration Aeration Oxygen Aeration Aeration
PET Operational Required Required Available Required Required Available
Condition (Ibs/day) (HP) (HP) (Ibs/day) (HP) (HP)
Phase I Start -Up 6,850 620 405 6,840 610 900
Phase I 10,350 930 405 10,340 910 900
Phase II 13,840 1,250 405 13,830 1,220 900
Table 28
Case A2: Aeration Capacity Assessment
Existing Facility Wastewater COD 5,800 mg/L, PET Wastewater COD 1,890 mg/L
1.2 MG Aeration Basin 4.4 MG Aeration Basin
Estimated Estimated Estimated Estimated
Oxygen Aeration Aeration Oxygen Aeration Aeration
PET Operational Required Required Available Required Required Available
Condition (Ibs/day) (HP) (HP) (Ibs/day) (HP) (HP)
Phase I Start -Up 5,980 540 405 5,970 530 900
Phase I 7,300 660 405 7,290 650. 900
Phase II 8,620 780 405 8,610 760 900
The assessment indicates that if the existing facility wastewater influent COD remains at the
5,800 mg/L condition experienced in June and July 2009 (or occurs in the• future), the existing
1.2 MG aeration basin does not have adequate aeration capacity to treat the increased COD load
that would result from the addition of the bottle recycle wastewater at even the best Phase I
start-up condition (PET wastewater COD at 1,890 mg/L). .
On the other hand, the 4.4 MG aeration basin appears to have sufficient aeration capacity for
practically the full Phase I condition over the range of effluent COD concentrations evaluated,
although conditions approach marginal (900 HP available versus an estimated 910 HP required) if
both the existing facility wastewater influent (COD at 5,800 mg/L) and the PET wastewater influent
(COD at 5,000 mg/L) were to remain at their worst case condition for several days. If data
collected during start-up confirms estimated aeration requirements and that existing
DAK wastewater and the PET effluent wastewater are likely to have CODs near their worst case
conditions, approximately 150 HP of additional aeration in the 4.4 MG basin for Phase I would be
warranted to allow for equipment downtime and transient peak Toads.
47

a
ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
If worst case conditions were to persist through Phase II, approximately 450 HP of
additional aeration would be required to allow for equipment downtime and peaks loads.
Case B: Historical COD, Existing Facility Wastewater at Total COD = 2,560 mg/L
Table 29
Case B1: Aeration Capacity Assessment
Existing Facility Wastewater COD 2,560 mg/L, PET Wastewater COD 5,000 mg/L
1.2 MG Aeration Basin 4.4 MG Aeration Basin
Estimated Estimated Estimated Estimated
Oxygen Aeration Aeration Oxygen Aeration Aeration
PET Operational Required Required Available Required Required Available
Condition (Ibs/day) (HP) (HP) (Ibs/day) (HP) (HP)
Phase I Start -Up 3,810 340 405 3,800 340 900
Phase I 7,310 660 405 7,300 650 900
Phase II 10,620 960 405 10,610 940 900
Table 30
Case B2: Aeration Capacity Assessment
Existing Facility Wastewater COD 2,560 mg/L, PET Wastewater COD 1,890 mg/L
1.2 MG Aeration Basin 4.4 MG Aeration Basin
Estimated Estimated Estimated Estimated
Oxygen Aeration Aeration Oxygen Aeration Aeration
PET Operational Required Required Available Required Required Available
Condition (Ibs/day) (HP) (HP) (Ibs/day) (HP) (HP)
Phase I Start -Up 2,930 270 405 2,930 260 900
Phase I 4,260 380 405 4,250 380 900
Phase II 5,580 500 405 5,570 490 900
For the Phase I start-up condition, assuming an" existing facility wastewater influent COD of
2,560 mg/L, this analysis shows that there is sufficient available aeration capacity in the
1.2 MG Aeration Basin for the probable range of bottle recycle wastewater
COD concentrations evaluated.
For the full Phase I condition, assuming an existing facility wastewater influent COD of 2,560 mg/L,
the available aeration in the 1.2 MG Basin is adequate assuming the best case condition of
1,890 mg/L of COD in the bottle recycle wastewater effluent; however, an estimated 660 HP of
aeration is required for the worst case condition of 5,000 mg/L COD in the bottle recycle
wastewater, which exceeds the available aeration capacity in this basin.
48

SAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
For the full Phase I condition, assuming an existing facility wastewater influent COD of 2,560 mg/L,
the available aeration capacity in the 4.4 MG gallon basin is adequate even for the worst case
condition of 5,000 mg/L COD in the bottle recycle wastewater.
For the Phase II condition, operation in the 4.4 MG basin is required and the analysis indicates that
the existing aeration equipment will be adequate if the bottle recycle wastewater effluent COD
remains below about 4,700 mg/L. At the worst case condition (PET wastewater at 5,000 mg/L),
however, the existing 900 HP of aeration capacity will be marginal at best (estimated requirement
is 940 HP) and inadequate to cover peaks or if an aerator is out of service.
It appears that the projected worst case aeration requirement in the 4.4 MG basin could be met by
relocating the two floating 75 HP Aire-02 aerators from the 1.2 MG basin. This would give a
total of 1,050 HP of aerators, providing a reserve of about 10% for equipment downtime or
transient peaks.
6.6 Estimated Sludge Production
The total estimated volume of sludge produced was estimated by calculating an observed yield
coefficient (Yobs), which is the net microbial growth rate, considering aerobic decay at the
operation sludge age. For this calculation a sludge age of 70 days was assumed:
(
Yobs=
Y
1+ KC
I)
,,
(
0.46mgVSS
mgCOD
(0.077�
1 + day
1
70day,�
= 0.07mg VSS/mg COD degraded
A review of the 2006 to 2008 operating data at the plant indicates a more typical value of
actual sludge yield on the order of 0.10 to 0.14 mg VSS/mg COD, which is reasonable value for a
sludge age of 70 days. Therefore, to be conservative, the overall sludge production was estimated
based on actual plant data, rather than this estimate and a value of 0.12 mg VSS/mg COD
was used.
49

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
The fraction of. non -biodegradable VSS in the bottle recycle wastewater -that is biodegradable was
assumed to be low. For fixed solids, assuming the pretreatment plant is operating appropriately, it
was assumed this value is also low in the PET bottle recycle effluent.
Based on observations of the existing facility wastewater during this study, the influent TSS . is
relatively low.. Based on 2006 to 2008 system operating data, the long-term average concentration
of non -biodegradable solids in the aeration basin is 560 mg/L. Using a generalrelationship
between the non -biodegradable solids in the aeration- basin, sludge age, and hydraulic retention
time6, the. estimated long term ` average non -biodegradable - solids concentration in the
existing facility wastewater was estimated at 50 to 60 mg/L.
For the assessment of sludge production, it was assumed the COD . concentration in the
existing facility wastewater was restored to the historical average value; therefore, only Case B
(existing facility wastewater total COD 2,560 mg/L, bottle recycle wastewater total COD ranging
between 1,860 to 5,000 mg/L) was evaluated.
The estimated sludge productionwas estimated by the followingequation and the results for Case'
B1 and Case B2 are presented in Table 31 and Table 32.
SP = Yobs(COD) + 8.34(Q)FSS
SP = solids production dry weight basis (lbs/day)
COD = COD loading (Ibs/day), assumes all COD removed in system
Q = _Flow (MGD)
FSS = Concentration of non-biodegradablesolids in influent wastewater (mg/L), assumed at
60 mg/L'for existing facility -wastewater and zero for bottle recycle wastewater (all solids in
bottle recycle wastewater effluent assumed as biodegradable)
6 Biological Process Design for Wastewater Treatment, 1985
50

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
Table 31
Case B1: Estimated Solids Production
Existing Facility Wastewater COD 2,560 mg/L, PET Wastewater COD 5,000 mg/L
PET Operational
Condition
Phase I Start -Up
Phase I
Phase II
Total
Existing Daily Total
Projected Average Average COD
PET Flow Daily Flow Flow Loading
(GPD) (GPD) (GPD) (Ibs/day)
58,500 170,000 228,500 5,744
201,000 170,000 371,000 11,031
347,600 170,000 517,600 16,306
Total Non -
Biodegradable
Solids Loading
(Ibs/day)
85
85
85
Estimated
Solids
Production
(Ibs/day)
774
1,408
2,041
Table 32
Case B2: Estimated Solids Production
Existing Facility Wastewater COD 2,560 mg/L, PET Wastewater COD 1,890 mg/L
PET Operational
Condition
Phase I Start -Up
Phase I
Phase II
Existing Total
Average Daily Total
Projected Daily Average COD
PET Flow Flow Flow Loading
(GPD) (GPD) (GPD) (Ibs/day)
58,500 170,000 228,500 4,429
201,000 170,000 371,000 6,427
347,600 170,000 517,600 8,421
Total Non -
Biodegradable
Solids
Loading
(Ibs/day)
85
85
85
Estimated
Solids
Production
(Ibs/day)
616
856
1,095
The data from 2006 through 2008 indicates an estimated annual average sludge production based
on TSS (dry basis) ranging from 474 to 589 Ibs/day.
For the full Phase I condition, sludge production is estimated to vary between 856 to 1,408 Ibs/day,
over the range of projected bottle recycle wastewater effluent COD values from 1,890 to
5,000 mg/L total COD. Assuming a Tong -term average COD of 3,445 mg/L (midpoint value of the
protected range), the full Phase I estimated sludge production is 1,132 Ibs/day, or about double the
-2006-2008 sludge production (estimated assuming the 2006-2008 existing facility wastewater
average conditions).
For the Phase II condition, sludge production is estimated to vary between 1,095 to 2,041 Ibs/day,
over the range of projected bottle recycle wastewater effluent COD values from 1,890 to
5,000 mg/L total COD. Assuming a long-term average COD of 3,445 mg/L (midpoint value of the
protected range), the Phase II estimated sludge production is 1,568 Ibs/day, or about triple
the 2006-2008 sludge production (assuming the 2006-2008 existing facility wastewater
average conditions).
51

SAFE
• Biological System Assessment Report
DAKAmericas, LLC,
;Fayetteville, North Carolina
November 2009 -
6.7 Evaluation of Existing Clarifier
The existing clarifier is a 90-ft diameter by 14-ft side water depth structure with a center feed well
and peripheral effluent launder.. It has an .Eimco:drive and double -armed rake with rapid removal
ports and piping for .withdrawing settled sludge from the floor. It was designed forflows up to
1.25 MGD, or about 868 GPM. The clarifier was assessed using recommended typical design values
for hydraulic loading rate (or overflow rate) and solids loading rate.
Overflow Rate
Fora 90-ft 'diameter clarifier, the design flow of-1.25 MGD is equivalent to a hydraulic loading rate
of 196 gallons per day per square ft (gpd/sf). This value is equivalent to the minimum'.
recommended value from the EPA . Manua/ for Suspended So/ids Removal for settling following
extended aeration, which recommends a range of 196 to 392 gpd/sf based on daily average
flow values.
At the anticipated average daily flows from the Phase I start-up through Phase II operation, plus
the existing facility average daily flow rate, the hydraulic loading rate on the clarifier wasestimated
torange from 36 and 81 gpd/sf.
Solids Loading Rate
The clarifier solids loading rate represents the total pound of solids applied per unit of clarifier
surface area per ;unit time, and includes the solids loading in the recycle flow. For SVI values Of
300 ml/g, the EPA Manua/ for Suspended So/ids Remova/indicates a design solids loading value of
10 lbs/day ft2.
The existing' return sludge pumping system is currently operated at about 868 GPM to provide
adequate velocity for the rapid sludge removal ports and piping.* This is -a high volumetric rate at
current .loadings, and it should continue to be more than adequate as the loading on the clarifier
increases to. anticipated .levels. • .
Assuming a recycle flow. of 868 GPM, the estimated TSS concentration corresponding 'to a solids
loading rate of 10 Ibs/day ft2 for three bottle flow scenarios is:.
Phase I Start Up:
Phase I:'
Phase II:
5,159 mg/L TSS
4,705 mg/L TSS
'4,315 mg/L TSS
52

SAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
- November 2009.
Using the existing 2006 to 2008 average TSS/VSS ratio of 1.17, the corresponding maximum
VSS concentrations are estimated as follows based on this solids loading value:
PhaseI Start Up:
Phase I:
Phase II:
4.409 mg/L VSS
4,021 mg/L VSS
3,688 mg/L VSS
These values were used to represent the maximum VSS concentration for the purpose, of this
assessment, which was assumed to be about 4,000 mg/L.
It is envisioned that the facility will continue to use a flocculating polymer to control pin floc and
promote good settling in the clarifier.
53

EA►SAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
7.0 CONCLUSIONS AND RECOMMENDATIONS
EnSafe .prepared this biological treatment assessment report to assess the potential impact of the
discharge of the pretreated bottle recycle wastewater to the existing conventional activated
sludge treatment system, and to assess if the existing activated sludge system has the capacity to
treat the increased COD loading.
The existing system contains two separate aeration basis, with volumes of 1.2 MG and 4.4 MG, or a
total of 5.6 MG of aeration capacity. At the current COD loading, only the 1.2 MG aeration basin is
utilized for treatment. The 4.4 MG aeration basin was idled several years ago due to the decrease
in COD loading after the Monsanto plant closure. A central objective was to determine if the
1.2 MG aeration basin can handle the increased COD from the bottle recycle wastewater for the
three flow scenarios considered (Phase I Start -Up, Phase I, Phase II).
The pretreated bottle recycle wastewater has significantly different characteristics, compared to the
existing organic chemical wastewater; in particular higher TDS, higher TSS, more non-ionic
surfactants, higher projected temperature, and higher pH. The TSS concentration from the
pretreatment plant is expected to vary between 100 to 600 mg/L on average. Based on the
unit process utilized for solids removal at the pretreatment system, it is envisioned the effluent TSS
will be primarily the finer fraction of the TSS (i.e., assumed large plastic -type solids removed),
which for the purpose of this assessment was assumed to be all biodegradable VSS that exerts a
COD demand.
The assessment included a study to assess the biological treatability of the pretreated bottle
recycle wastewater (40% by volume) blended with the existing wastewater (60% by volume).
Two different conditions of PET bottle recycle wastewater were simulated: fully treated —
representing an effluent condition of low TSS, and partially treated — representing an estimated
effluent TSS condition on the order of about 900 mg/L. This TSS concentration was assumed as
a maximum.
The projected range of bottle recycle wastewater effluent COD concentrations used in this
assessment are summarized as follows:
• Best Case: Total COD of 1,890 mg/L (assumed TSS of 100 mg/L)
• Worst Case: Total COD of 5,000 mg/L (assumed TSS of 900 mg/L)
54

ENSAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
For the existing facility wastewater, the 2006 to 2008 average existing facility wastewater average
flow rate of 170,000 GPD and average COD of 2,560 mg/L (or 3,639 lbs/day) were assumed for
this assessment.
A review of the historical data indicated that the COD concentration from 2006 to 2008 was
relatively consistent, with a 3-year maximum monthly average concentration of 3,553 mg/L
(or 5,037 lbs/day at 0'.170 MGD).
During the course of the treatability study, EnSafe observed that the existing facility wastewater
COD concentrations were much higher than historical data; however, at that time the difference
was not understood. During preparation of this report and a review of the actual wastewater
operational logs for June and July 2009, the plant records also indicated much higher influent
COD concentrations, generally in the same range as EnSafe testing data. Thereafter, EnSafe
learned that a unit process upset condition occurred during this period, whichresulted in
significantly higher COD loadings. The average COD measured by EnSafe during the study was
5,800 mg/L. EnSafe understands a repair of the unit process upset requires a plant shutdown;
therefore, higher COD loading will continue for some time. Based on discussions with DAK;
EnSafe understands that this higher COD loading condition is likely to persist after start-up of the
bottle recycle plant.
Therefore, as a result, EnSafe evaluated two conditions based on COD concentration for the
existing facility wastewater, assumed to represent the average case and peak case.
• Average Existing Facility Loading: Total COD 2,560 mg/L (3,629 Ibs/day)
• Peak Existing Facility Loading: Total COD 5,800 mg/L (8,223 lbs/day)
For this assessment, three discharge scenarios were evaluated based. on the projected bottle
recycle wastewater flow rate. These discharge scenarios were developed based on information
provided by CPR and are summarized as follows:
• Phase I Start -Up: 2,000 kg/hour production capacity: 58,500 GPD
• Phase I: 7,000 kg/hour production capacity: 201,000 GPD
• Phase II: 12,000 kg/hour production capacity: 347,600 GPD
55

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
Summary of Cases Evaluated
Using this information, the following case scenarios were developed and evaluated, based on the
bottle recycle flow rate and the range of possible COD concentrations assumed for each
wastestream to determine a COD loading. The cases and associated COD loading are summarized
in Table 33. In all cases, the 2006 to 2008 average daily existing facility wastewater flow rate
was utilized.
Table 33
Summary of Cases Evaluated
PET Flow . Case Al Case A2 Case B1 Case B2
Rate COD COD COD COD
Case Scenario (GPD) (Ibs/day) (Ibs/day) (Ibs/day) (Ibs/day)'
Existing Wastewater COD (mg//L) 5,800 5,800 2,560 2,560
PET Wastewater COD (mg/L) 5,000 1,890 5,000 1,890
Phase I Start -Up 58,500 10,337 9,020 5,740 4,430
Phase I 201,000 15,625 11,020 11,030 6,430
Phase II 347,600 20,900 13,020 16,040 8,420
Biokinetic and Oxygen Use Coefficients
From the treatability study,. biokinetic and oxygen use coefficients were estimated for the
40%/60% blend of the fully pretreated bottle recycle wastewater and existing facility wastewater
based on soluble COD. The estimated coefficients are summarized as follows:
Specific substrate utilization rate constant (K) = 0.00012 L/mg hour
Yield Coefficient (Y) = 0.46 mg VSS/mg VSS
Aerobic Decay Coefficient (Kd) = 0.077 per day
Oxygen Use Coefficient for Synthesis (A) = 0.66 Ib 02/Ib COD
Oxygen Energy of Maintenance Coefficient (B) = 0.0072 Ib 02/Ib VSS day
For the case scenarios developed, these coefficients were then used to predict the steady state
VSS concentration in the aeration basin and the oxygen requirement.
Although these coefficients were developed for the 40%/60% blend of fully pretreated bottle
recycle wastewater and existing facility wastewater and are based on soluble COD, they were
utilized in all case scenarios. This approach was assumed valid based on a comparison of data
obtained from the reactors. This direct comparison of data suggests that the slowly degrading
56

F SAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
soluble COD in the existing facility wastewater is controlling and the rate of hydrolysis of particulate
COD is less than the rate of substrate utilization of the slowly degrading COD.
Reactor Operational Results
The reactor operation results indicated essentially complete removal of the soluble readily
biodegradable COD and CBOD at a sludge age of about 70 days. This is consistent with the
operational sludge age in the plant. This result, in conjunction with the estimated substrate
utilization rate, suggests that at a 40%/60% blend, the fully treated bottle recycle wastewater was
amenable to treatment and did not negatively impact the removal of the slowly degrading organics
in the existing facility wastewater at a sludge age of 70 days.
By direct comparison of the results from the fully treated reactor to the partially treated reactor
operated at about the same sludge age, the particulate COD was predominately solubilized
and biodegraded.
The settling characteristics of the mixed liquor produced in the reactors fed with fully pretreated
bottle recycle wastewater/existing facility wastewater blend were worse, when compared to the
control reactor operating at approximately the same sludge age, as indicated by SVI. SVI values
for the fully pretreated bottle recycle wastewater/existing facility wastewater blend averaged
231 ml/g; however, values between 300 to 350 ml/g were observed during the study.
Alternatively, the mixed liquor in the reactor fed with partially pretreated bottle recycle wastewater
receiving TSS/VSS in the pretreated effluent settled very well, in fact, better than the control
reactor. It is speculated the fine solids present in the bottle recycle wastewater acted as a
settling aid and improved settling performance. This data suggests the presence of solids in the
pretreated effluent is advantageous and appears to enhance settling.
Total Dissolved Solids
At the 40%/60% blend, based on the rounded average of the TDS concentrations of each
individual wastestream (500 mg/L existing facility . wastewater, 5,000 mg/L bottle recycle
wastewater) the estimated blended TDS concentration was about 2,300 mg/L. Therefore, the
overall substrate utilization rate constant is specific to this TDS concentration. Higher
TDS concentrations may reduce the overall substrate utilization rate. Some literature references
indicate a significant reduction in the overall substrate utilization rate as the TDS concentration
increases above 0.5% (or 5,000 mg/L).
57

ENS/IFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
For the Phase II condition, the projected percentage is 67% bottle recycle wastewater and 33%
existing facility wastewater, which at the aforementioned conditions indicates a blended
TDS concentration of about 3,500 mg/L (or about 0.35%). This TDS condition was not evaluated
in the treatability study, but it is reasonable to assume the overall substrate utilization rate could
decrease as the TDS concentration increases impacting performance. Additionally, as the TDS
increases, the oxygen transfer rate and biomass settling may be negatively affected.
Case Assessment Summary
For the case scenarios presented, the aeration basin temperature, projected aeration basin
MLVSS concentration, and oxygen requirement were estimated, assuming operation in either the
1.2 MG or the 4.4 MG basin at a sludge age of 70 days.
Operational risks were identified based on the following conditions:
• Aeration basin temperature of greater than 35 °C
• MLVSS concentration outside of 1,000 to 4,000 mg/L
• Oxygen requirement greater than oxygen available
For the Phase II bottle recycle flow rate, regarding aeration basin temperature, assuming the
2006 to 2008 peak monthly average temperature in the existing facility wastewater, along with a
bottle recycle wastewater temperature at the discharge of the equalization tanks of 45 °C, it is
apparent that the maximum allowable activated sludge temperature of 35 °C would be exceeded in
the 1.2 MG aeration basin during the peak month. Therefore, in the current configuration, the
1.2 MG aeration basin would not be viable for Phase II based on projected temperature.
Case A: Upset COD Loading, Existing Facility Wastewater at Total COD = 5,800 mg/L
It is clear from this analysis that if the existing wastewater COD remains at 5,800 mg/L, the 1.2 MG
basin is not adequate to handle the increased COD load from the bottle recycles wastewater,
even during the Phase I Start -Up condition, regardless of the COD concentration in the bottle
recycle effluent.
Under this scenario, operation in the 4.4 MG basin would be required. The aerators installed in this
basin (900 HP) appear to have sufficient aeration capacity for practically the full Phase I condition
over the range of effluent COD concentrations evaluated, although conditions approach marginal
(an estimated 910 HP required) if both the existing facility wastewater influent (COD at
5,800 mg/L) and. the PET wastewater influent (COD at 5,000 mg/L) were to remain at their
58

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Biological System Assessment Report
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Fayetteville, North Carolina
November 2009
worst case condition for several days. Using the discounted oxygen transfer efficiency and the
conservative oxygen transfer coefficient, the aeration assessment may tend to overestimate the
aeration required.; however, it is reasonable to assume additional aeration would be necessary. It
is recommended that data be collected during start-up to confirm estimated aeration requirements.
If these are confirmed and it is found that existing DAK wastewater and the PET effluent
wastewater are likely to have CODs near their worst case conditions, additional aeration in the
4.4 MG basin for Phase I would be warranted to allow for equipment downtime and transient
peak loads.
Case B: Historical COD, Existing Facility Wastewater at Total COD = 2,560 mg/L
For Case B, the three flow scenarios for the bottle recycle wastewater were evaluated at the range
of possible bottle recycle COD concentrations from 1,890 mg/L to 5,000 mg/L.
Phase I Start -Up Condition
For the Phase I start up condition (58,500 GPD bottle recycle wastewater), the estimated
COD loading is presumed to vary from 4,430 to 5,740 Ibs/day over a bottle recycle
COD concentration of 1,890 to 5,000 mg/L.
1.2 MG Aeration Basin
Based on the temperature assessment, assuming a bottle recycle wastewater discharge
temperature of 45 °C, the projected aeration basin temperature during the peak month was
estimated at 32.5 °C to 34.9 °C, which is within the acceptable range; however, this indicates
a practical maximum temperature limit for the bottle recycle wastewater of 45 °C during the
start-up phase.
Based on the VSS concentration assessment, the estimated MLVSS concentration is the 1.2 MG
aeration basin is 2,920 to 3,582 mg/L (allowing for the 700 mg/L adjustment), over a bottle recycle
COD concentration of 1,890 to 5,000 mg/L. This is a reasonable MLVSS concentration range and
within the limits of the clarifier.
Based on the aeration assessment, the 405 HP of aeration capacity would be adequate for the
range of expected conditions.
59

ENSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
4,4 MG Aeration Basin
The estimated MLVSS concentration in the 4.4 MG aeration basin was projected at 1,306 to
1,486 mg/L (allowing for the 700 mg/L adjustment), over a bottle recycle COD concentration of
1,890 to 5,000 mg/L. This is a fairly low MLVSS concentration and settling performance could be
negatively impacted.
For the Phase I start-up condition, operation in the 1.2 MG basin is recommended.
Full Phase I Condition
For the full Phase I condition (201,001 GPD bottle recycle wastewater), the estimated COD loading
is presumed to vary from 6,427 to 11,031 Ibs/day, over a bottle recycle COD concentration of
1,890 to 5,000 mg/L.
1,2 MG Aeration Basin
Based • on the temperature assessment, assuming a bottle recycle wastewater discharge
temperature of 45 °C, the projected aeration basin temperature during the peak month was
estimated at 37.2 °C to 38.7 °C, which is above the practical maximum allowable for the activated
sludge process of 35 °C.
Again, temperature estimation was based on a simplistic approximation and actual temperature in
the 1.2 MG basin may be less; however, this assessment indicates that for the full Phase I
condition, the bottle recycle wastewater temperature maximum would most likely need to be Tess
than 45 °C at the discharge to the existing equalization tanks, probably on the order of 40 to 41 °C;
otherwise, additional surface aerators may be needed to provide cooling to control the aeration
basin temperature to less than 35 °C for the peak month.
Based on the VSS concentration assessment, the estimated MLVSS concentration is 3,921 to
6,289 mg/L (allowing for the 700 mg/L incremental adjustment), over a bottle recycle
COD concentration of 1,890 to 5,000 mg/L. This indicates that at the higher end of the expected
range of the bottle recycle COD concentrations evaluated, the MLVSS would exceed the desired
range, which appears could result in settling issues.
Based on the aeration assessment, using the discounted transfer efficiency and the conservative
oxygen transfer coefficient, the existing 405 HP of existing aeration capacity would be adequate for
the best case 1,890 mg/L COD concentration in the bottle recycle wastewater; however up to an
additional 250 HP of additional aeration capacity could be required at the worst case of 5,000 mg/L
60 ,

ENSAFE
Biological System Assessment Report,
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
in the bottle recycle wastewater. As discussed, this aeration assessment may overestimate the
.amount aeration required; however, it is clear that additional 'aeration is required for operation in
the 1.2MG aeration basin for the Phase I condition.
For the Phase I condition, operation in the 1,2 MG aeration basin is marginal. For this to be
possible, the effluent COD from the bottle recycle plant would need to be near the optimum of
1,890 mg/L, with the existing facility wastewater at 2,560 mg/L.
Considering these three factors, ' combined with the inability to handle peak, loading - or
upset conditions with high COD in the existing facility wastewater for the full scale Phase I
condition, operation in the 4.4 MG basin is recommended and operation in this basin was assessed.
4,4 MG Aeration Basin
As discussed, estimating the amount of cooling for the Phase. I flowrate in the 4.4.MG basin was •
beyond the scope of this project. However, given the higher surface area compared to the 1.2 MG -
aeration basin and number and size of surface aerators,the amount of heat loss is envisioned to be
higher than the 1.2 MG basin. It is recommended the actual bottle recycle wastewater temperature
be .determined during the start-up condition and a detailed heat balance assessment be conducted.
Based on theaeration assessment, using the. discounted transfer efficiency and the conservative
oxygen transfer coefficient, the existing 900 HP of existing aeration capacity would be adequate to
meet even the estimated demand of 650 HP for the worst case,.COD of 5,000 mg/L .in: the bottle
recycle wastewater.
Phase II Condition
For the Phase II condition (347,600 GPD- bottle recycle wastewater), the estimated. COD loading is.
presumed to vary from 8,420 to 16,040 Ibs/day, over a bottle recycle COD ' concentration of
1,890 to 5,000 mg/L.
As discussed; for the Phase II flow rate, operation in the 1.2. MG aeration basin is not, possible from
a temperature, MLVSS and available aeration standpoint.
4,4 MG Aeration Basin
As discussed; estimating the amount of coolingfor, the Phase II flow rate in the 4.4 MG basin was.
beyond the scope of this project. It is recommended temperature data be collected during Phase I
Start-Up/Phase I; operation and a detailed heat balance assessment be conducted prior to Phase II.
61,

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Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
Based on the VSS concentration assessment, the estimated MLVSS concentration is 1,851 to
2,933 mg/L (allowing for the 700 mg/L incremental adjustment), over a bottle recycle
COD concentration of 1,890 to 5,000 mg/L. This is a reasonable MLVSS concentration range.
Based on the aeration assessment, using the discounted transfer efficiency and the conservative
oxygen transfer coefficient, the existing 900 HP of existing . aeration capacity would become
marginal if the bottle recycle effluent COD concentration approached its worst case. Furthermore,
there would be no reserve aeration capacity to meet transient peaks or allow for
equipment downtime. It is recommended that wastewater loadings and aeration performance be
monitored during Phase I. If the conclusions and assumptions of this study are confirmed,
additional aerators would be warranted in the 4.4 MG basin prior to Phase II. It appears that this
projected aeration requirement could be met by relocating the two floating Aire-02 aerators from
the 1.2 MG basin.
Other Conclusions
In addition, the following conclusions are provided based on knowledge of plant operations, a
review of the permit, and the characteristics of the bottle recycle wastewater. Some of these
conclusions were previously presented in the Pretreatment System Engineering Report.
• For the projected Phase I condition, there appears to be a risk of exceeding the 0.500 MGD
monthly average flow limit during a peak monthly condition with the stormwater
contribution. For the projected Phase II flow conditions, the projected daily average flow
rate will exceed the 0.500 MGD monthly average flow limit.
• The permitting approach selected by the NCDENR results in decreasing concentration limits
(BOD, TSS, and ammonia) with flow, as no specific allocation was made for the
CPR discharge. Using the combined projected Phase I flow rate and the 2006 to 2008
average facility flow rate (0.371 MGD), the estimated monthly average warm season BOD,
TSS, and warm season ammonia concentration limits are 14.8 mg/L, 24 mg/L, and
4.2 mg/L, respectively.
• Considering the reduced ammonia limit, EnSafe recommends an upgrade to the existing
nutrient feeding system and nutrient control program to achieve a more balanced
nutrient addition, relative to COD loading.
62

SAFE
Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
As a nitrogen supplement, EnSafe understands 'urea is dosed directly to the pH, pit. The pit
IS relatively quiescent, with no mechanical mixing. The amount of ureaadded is based on
the influent COD (measured once per day). Urea appears to be added at a ratio ofabout
5 Ibs of . nitrogen per 100 .lbs of influent COD. Also, EnSafe understands the nutrient
metering rate may be adjusted (or trimmed) based on the effluent ammonia residual. =
This method is effectively a daily average feedback type nutrient control strategy, where
nutrients are added based on the previous day average COD loading. EnSafe suggests that
a more reliable nutrient strategy be developed which willmore closely match nutrient
requirements withactual organic loading.
The measured TDS .in the DAK wastewater (about 500 mg/L) compared to pretreated bottle
recycle wastewater (4,840 mg/L to 5,500 mg/L) is significantly different. The system should
be operated to minimize short-term changes in TDS concentration, as this could negatively
impact performance.
The measured CTAS surfactant concentration in the fully pretreated .and partially pretreated
wastewater. ranged from 120 to 110. mg/L. The results for the biological treatability study
indicated a projected effluent concentration of 10 to 20 mg/L, indicating some :residual CTAS
surfactant was present in the discharge and not fully biodegraded. During the
treatability study, some foaming was observed in the effluent upon agitation, suggesting
some residual surfactant may be present. Obviously, the treatability study was performed
using the wastewater, samples provided by CPR, in which those specific surfactant(s) used in
the: process chemistry were not known. EnSafe recommends that CPR select surfactant(s)
that are readily biodegradable.' Additionally, CPR should evaluate the aquatictoxicity data
of the proposed surfactant(s) and select a surfactant with low aquatic toxicity. -
Foaming may be an issue in:thefinal effluent and foam control may be necessary.'
• The . pretreatment system . effluent is proposed for discharge to' the existing equalization
tanks (or, to a single tank). ' The effluent from the pretreatment'system will contain residual,
relatively fine solids. Although residual TSS/VSS is of a small particle size, it will settle over
'time and could cause maintenance issues'in this tank if not agitated.' EnSafe recommends
mixing be considered in this tank:
63

Biological System Assessment Report
DAK Americas, LLC
Fayetteville, North Carolina
November 2009
• The total phosphorus in the bottle recycle wastewater sample was measured at 12.8 mg/L;
however, the indicated process chemical contained 5 to 7% phosphorus. If a
process chemistry with a high phosphorus concentration is used, this could be a concern for
discharge to PWC, with a total phosphorus permit limit of 3.0 mg/L. Although there is not a
proposed phosphorus limit in the current NPDES permit, phosphorus is a "report only"
parameter. Therefore, this provides for the possibility of a future phosphorus limit, should
effluent data indicate concentrations of concern.
Recommendations
EnSafe understands that the Phase I Start-up condition (2,000 kg/hr production at 58,500 GOD) is
planned for spring 2010, with the full Phase I condition (7,000 kg/hr production at 210,000 GPD)
planned for late 2010.
Based on this information, it appears there is about 6 to 8 months between Phase I Start -Up and
full Phase I.
Assuming that the unit process upset condition is repaired and the existing facility wastewater COD
is at historical conditions, the existing 1.2 MG basin is adequate both volumetrically and in terms of
aeration capacity to treat the Phase I Start -Up bottle recycle wastewater over the range of
wastewater conditions evaluated (COD of 1,890 mg/L to 5,000.mg/L).
Therefore, EnSafe recommends initial operation in the 1.2 MG aeration basin during this period.
The 6 to 8 month timeframe could be utilized to obtain actual data on the characteristics of the
bottle recycle effluent and actual discharge rates, along with a better understanding of the
possible reduction in oxygen transfer efficiency in the aeration basin.
This would allow a more accurate assessment of the capacity of the 1.2 MG basin capacity for the
full scale Phase I condition. As discussed, based on the current information provided by CPR on
projected flow rates and estimated loading, operation in the 1.2 MG basin is at best marginal, and
additional aeration capacity is necessary; therefore is not recommended. However, if actual
COD loading from CPR is less; either due to lower wastewater discharge rates than assumed
(for this assessment bottle recycle wastewater flow based on 4 L/kg, however originally 2.5 to
3.0 L/kg was proposed) or lower COD concentrations than projected, operation in the 1.2 MG might
be possible for the Phase I condition. A reassessment could be conducted based on actual
operating data.
64

£uSAFE
Biological System Assessment Report
DAKAmericas, LLC
Fayetteville, North Carolina
November 2009
If the unit process upset condition is not repaired prior to initiation of CPR discharge or the Phase I
operational period is not available for actual full scale data collection, EnSafe recommends
operating in the 4.4 MG basin and making provisions to provide up to 150 HP of additional aeration
prior to Phase II. At this time, based on current information, it appears that this projected aeration
requirement could be met by relocating the two floating Aire-02 aerators from the 1.2 MG basin.
Prior to receipt of bottle recycle wastewater in the existing system, a start-up plan needs to
be developed for acclimation of the biomass to the different characteristics of the bottle
recycle wastewater.
G:\A-L\DAK Americas\DAK Cedar Creek\Biological System Design Report\DAK Biological System Assessment Report.doc
65

Appendix A
NPDES Permit and Rationale
I

A, r
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
August 6, 2009
Craig Leite, Cedar Creek Site Manager
DAK Americas LLC
3468 Cedar Creek Road
Fayetteville, North Carolina 28301
DeeFreeman
Secretary
•
Subject: Issuance o \.NPDES Perinit.NC0003719
DAK:Americas,• LLC ~Cedar Creek �ite
3-46.8,Cedkr.Creel�,Road' �' r' ;
FayettevilleNC.283g1. s'( `.;'1;/
<; Cumberland.C.ounty _\ \
Dear Mr. Leite: \
The Division of Water Quality,00 or the`Division) Hereby issues this permit pursuant to the
requirements of North Carolina` General Statute,;143-215.1. and the Memorandum of Agreement
between North Carolina a'i -he Ll*En ironmental Protection Agency dated October 10, 2007,
or as subsequently inended�\\�� . `, /
DAK submitted reiiminary c �mj tso '•.the draft' permit on May 08, 2009; met with DWQ on
May 22, 2 - '9; and\ mitte'd final co s includin a revised Engineering Alternative
rr\ g g g
AnalysisA'AMon May29, 200% ased`sthis correspondence and review, the Division offers
the following\discus s��n\of the eri it FINAL:
1. Flow and Facility drade. DAK's request, DWQ has revised the permitted flow from
0.300 MGD permit)"td 0.500 MGD. This request is hereby granted. DAK will
therefore remain' 'Gracile III WWTP consistent with the previous permit. Likewise,
monitoring frequencies of 1/Week (draft permit) are revised to 3/Week reflecting
requirements for Grade III.
2. DRAFT Special Condition A. (5.). The Division also revised Special Condition A. (5.)
based on DAK's latest Engineering Alternative Analysis (EAA) received May 29, 2009
concluding that treated discharge to Fayetteville PWC represents a 22% increase in annual
operating costs. DWQ concurs that 22% represents a significant cost increase over a direct
discharge to the Cape Fear River. Therefore DAK may continue treated wastewater
discharge to surface waters of the state, and DWQ will consider permit renewal according to
the Cape Fear River Basin Schedule.

Issuance of NPDES permit NC0003719
DAK Americas LLC
Page 2 of 3
3. Proposed Plastics Recycling Facility (PRF) — Revised Special Condition A. (5.). Contrary to
the draft permit, PRF construction does not require an Authorization to Construct (ATC)
Permit. However, an ATC is required for any additional treatment units or processes
necessary to treat PRF wastes. Therefore, during construction of the proposed PRF (with
process -contact flow estimated at 0.111 MGD), DAK shall designate a sampling location, as
Internal Outfall 001, influent to the onsite WWTP whereby the Permittee may sample and
analyze PRF samples prior to mixing with other wastes. No later than 90 days prior to
receiving wastes from said PRF, DAK will provide a written report characterizing PRF
wastes generated under SIC 5162, in accord with revised permit Special Condition A. (5.).
4. Permit Limits - Recalculation. For permit issuance, DWQ recalculated draft permit limits
and monitoring conditions using OCPSF=regulated flow only.,The Division used the agreed -
upon long-term average of 0.228 MGD, excluding non-OcPSF.regulated\flow proposed for
PRF wastes from SIC Code 5162 [see permit section A. (F.)], D Qrecakulated OCPSF
§414.41 limits as:
0.22 \ ` ` `� `� `• • Flow • ( 8 MGD) x 64 mg/L x 8.31�i6s/,gal`for DaityMaximum, and`. . .•
• Flow (0.228 MGD) x 24 mg/L x 8.34\1b/gal for' th thly,Average
DWQ also recalculated §414.91 9b'forr v\e zd of pip bio=treatmen ',[see permit section A.
(1.)]. This required final limirev ons because water\\quality standards are more stringent
for: K \\.\
\.,
\\
_\ \\ /'. \\
Parameter •
Daily ..
-;,.,_•__
Max.;..- :
:..NLoritlily, ':
:: : -::.-:... .
-,::Aerage-•': ,
Frequency
:. :•' :::-:,::._;
•
.` Type::.-
; ::: __ _:. ,,.,, :.:..
Location
2,6-Dinitrgtoluerie,
49, 0, µg/L,,'
d 4,g5 g/L
1/Quarter
Grab
Effluent
Hexachl`orgbenzerie.., 1.6 µg/L\
'0.004g/L
1/Quarter
Grab
Effluent
5. Total Residual C41lorine,(TRC) — A TRC limit has been added to the permit (28 ug/L),
consistent with the`new"statewide standard for chlorine. However, compliance is required
only if chlorine is used,and because of difficulties quantifying TRC in a wastewater matrix,
values detected below 50 ug/L will be considered compliant with this permit [see permit,
Part 1. (A.), TRC footnote].
6. Stormwater Outfalls — DAK has requested the Division to combine wastewater point -source
permitting with existing stormwater outfalls permitted under NCS000389. The Division
must deny this request as it moves toward separating wastewater and stormwater permits
statewide due to significant complications governing permit monitoring and renewal.
Therefore, all stormwater outfalls previously attached to this permit are hereby transferred
and will be reviewed and renewed as appropriate under the requirements of stormwater
permit NCS000389 (in progress).

Issuance of NPDES permit NC0003719
DAK Americas LLC
Page 3 of 3
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing upon written request within thirty (30)
days after receiving this letter. Your request must take the form of a written petition conforming to
Chapter 150B of the North Carolina General Statutes, and must be filed with the office of.
Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless
such demand is made, this permit remains final and binding.
This permit is not transferable except after notifying the Division of Water Quality. The Division may
require modification, or revocation and re -issuance of this permit. Please note that this permit does
not affect your legal obligation to obtain other permits required by the-Dvisio of Water Quality, the
Division of Land Resources, the Coastal Area Management Act, or otherrfedera `or local governments.
�\�\ \
\..\ \�\
If you have questions, or if we can be of further service, please cone cke C or n\a . ,/\
[Joe.Corporon@a,ncdenr.gov] or call [phone]`' \ \ e, \ �',,, \ i
i �� Respectfully\ \\\`\\\\ \-\>
\\
y \ `
\\\ \�
\\ '\,`, \\
\ \\\ \ \: /ColeenYHSullins
\\
C,J
Enclosure: NPD it\N
cc: Fayettevillee Re,'onal of ice Surface Water Protection Section, Attn: Mark Brantley
NPDES Program )I
PERCs Unit [e-copy`],/
Technical Assistance\apd Certification Unit [e-copy]
Stormwater Permitting Unit, Attn: Jennifer Jones [e-copy]
Aquatic Toxicology Unit, Attn: Susie Meadows [e-copy]
EPA Region 4, Attn: Marshall Hyatt [permit + application]
DAK Americas LLC, Attn: Elizabeth Wike (ORC)
3500 Daniels Road, N.E., Leland, NC, 28451,

DAK Americas LLC — Cedar Creek Site
NPDES Permit NC0003 819
Fact Sheet Addendum - Renewal/Permit Final Development
Fact Sheet Addendum
July 31, 2009
Joe Corporon, L.G.
NPDES Program
for NPDES Permit Final Development
After reviewing DAK's preliminary comments on the draft permit (received May 8, 2009), meeting
with the Permittee on May 22, 2009; and reviewing DAK's final comments and revised Engineering
Alternative Analysis (EAA) received May 29, 2009, the Division has revised the draft permit:
1. DAK requested that DWQ reinstate the permitted flow from 0.300 MDG (draft permit) to
0.500 MGD to allow for future expansion. The Division can foresee no adverse impact to the
receiving stream and therefore has no objection noting that 0.500 MGD represents an
instream waste. concentration (IWC) to the Cape Fear River of 0.10%. The.Division will
therefore revise the permit final by reinstating the WWTP to the pre -draft Grade III status
with monitoring frequencies at 3/Week. •
2. DWQ hereby rescinds draft permit Special Condition A. 5. DAK may therefore continue
discharging treated wastewater to surface waters of the state, and DWQ will consider permit
renewal according to the Cape Fear River Basin Schedule. However, DWQ has revised
Special Condition A. (5.) to require the Permittee to establish a sampling point for the
proposed plastics recycling facility PRF-generated wastes prior to mixing with other wastes
influent to the onsite WWTP, and to evaluate and report following study to more accurately
characterize and quantify PRF effluent.
3. The Division must deny the Permittee's request to recalculate WWTP permit limits by adding
0.111 :MGD flow for the (PRF). This request is denied because the PRF does not generate
OCPSF wastes (SIC code 5162). Therefore, DWQ recalculated limits for the permit final
using the DAK-recommended agreed -to long-term flow average of 0.228 MGD applied to
OCPSF §414.41 using the equation:
a. Flow (0.228 MGD) x 64 mg/L x 8.34 lbs/gal = BODS Daily Maximum
b. Flow (0.228 MGD) x 24 mg/L x 8.34 lbs/gal = BODS Monthly Average
c. Flow (0.228 MGD) x 130 mg/L x 8.34 lbs/gal = TSS Daily Maximum
d. Flow (0.228 MGD) x 40 mg/L x 8.34 lbs/gal = TSS Monthly Average
DWQ also applied 0.228 MGD to 40CFR §414.91 9b for "end of pipe bio-treatment" [see
permit section A. (1.)]. These calculations dictate water -quality based limits for two
parameters because the stream standards are the more stringent of the two REGs. [see A. (1.),
OCPSF table continued]:
Parameter
Daily Max
Monthly Average
2,6-Dinitrotoluene
49.0 µg/L
0.48 µg/L
1/Quarter
Grab
Effluent
Hexachlorobenzene
1.6 µg/L
0.03 µg/L
1/Quarter
Grab
Effluent

DAK Americas LLC — Cedar Creek Site
NPDES Permit NC0003819
Fact Sheet Addendum Renewal/Permit Final Development
4. Ammonia Nitrogen (NH3) History — Consistent with previous permits, and receiving stream
modeling, DWQ calculated a summer Monthly Average ammonia nitrogen (NH3) limits for
renewal based on an equivalent mass -to -flow ratio.
Previous limits:
• 0.859 MGD - corresponding to summer Monthly Average limit of 23 lbs/day
• 1.25 MGD - corresponding to summer Monthly Average limit of 35 lbs/day
For renewal, Ammonia at 0.500 MGD:
• 13 lbs/day Monthly Average (summer)
• 26 lb./day Daily Maximum (summer - doubled the Monthly Average)
• 26 lbs/day Monthly Average (winter - doubled the summer Monthly Average)
• 52 lbs/day Daily Maximum (winter - doubled the Monthly Average)
•
Winter limits are double the summer months since dissolved oxygen is less of a concern
during the colder season. The Division judges these limits consistent since 1995 and
appropriate for renewal.

Permit NC0003719
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provision of North Carolina General Statute,143 21<5..1, other lawful standards
and regulations promulgated and adopted by the North Carolini,Enviroh ental Management
Commission, and the Federal Water Pollution Ca\ trol�2k,a, as an ended,.
`\� \ `�
,\ sue.
r
DAK Amen as\ '\ /'
is hereby authorized to discharge wast• ewater rom\a fac 1ityioca£ed at
DAKAm•
er�icas LLG- Cedar Creek Site
3 46 8`• dar'� Lek R ad, Fayetteville
�` , \ \\•
\\Gum erland County
) \N
to receiving waters desigi tefl as-t ap.� Fear River in the Cape Fear River Basin in accordance with
effluent limitations .kr onito%ig r�quireine s and other conditions set forth in Parts I, II, III and .IV
hereof. \ .\\\
`,` \\
This permit shall become effectiee September 1, 2009.
This permit and authorization to discharge shall expire at midnight on October 31, 2011.
Signed this day August 7, 2009.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0003719
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions described herein.
DAK Americas LLC
is hereby authorized to:
1. continue to operate an existing 0.300 MGD wastewater treatment:plant (WWTP) consisting of
• flow equalization,
• spill basin
• pH adjustment
• oil skimming
• dual aeration basins
• clarifier
• sludge pump station ,
•
•
located at t4,-DAK `Americai\LL.d.,\-,-,(ec\far.Oeek Site, 3468 Cedar Creek Road, south of Fayetteville
2. after receiving arikithortz#orhto Construct (ATC) permit from Construction Grants and Loans
for new wastewateKtKeatnieni\tinits/processes (if any) required to treat process -contact wastes
from the proposed plsties'reeycling facility (PRF), construct and operate a PRF with wastes
influent to the existing cinsite wastewater treatment plant via newly designated internal Outfall 001
(to be located during PRF construction upstream of any and all wastewater treatment); and "
3. after completing PRF waste -characterization, [See Special Condition A. (5.)], and upon
completing construction of any new waste treatment units, submit an Engineer's Certification form
requesting authorization to operate, and after receiving an Authorization to Operate (ATO) from
the Division,
4. discharge from .said treatment works and plastics recycling facility via Outfall 002 (located on the
attached map) into the Cape Fear River, a Class C waterbody within the Cape Fear RiverBasin.

Permit NC0003719
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge from Outfall 002. Such discharges shall be limited and monitored by the Permittee as
specified below:
Effluent
Characteristics
Limits
Monitoring
Requirements
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location 1
Flow
0.500 MGD
Continuous
Recording
I or E
Total Suspended Solids (TSS)
76 lbs /day
247 lbs/day
3/Week
Composite 2
E
BOD5, 20°C (April 1 — October 31)
46 lbs /day
122 lbs /day
3/Week
Composite 2
E
BOD5, 20°C (November 1— March 31)
92 lbs /day
244 lbs /day
3/Week
Composite 2
E
NH3-N (April 1-October 31)
13 lbs /day
26 lbs /day
3/WeeJc.•
Composite 2
E
NH3-N (November 1 —March 31)
26 lbs /day
52 lbs /day
3/,Week'••: •.,,
Composite 2
E
Fecal Coliform (geometric mean)
3zWeek ' `
Grab
E
Total Residual Chlorine 3
28 µg/L
\ \, 3/Week` \ •
_,\. Grab
E
Temperature (°C)
..-•,,
`A./Week \;'•..
'•\"Grab
E
Dissolved Oxygen 4•
:~ ., `;
3/W(eelrt ` ; r'
N., Grab, -
E
pH •
Not <6.0 nor > 9.0 staridaid units `
4 ;;.;' 3./Week \• -
' `3'/Week,/
E
Total Nitrogen (NO2 + NO3 + TKN)
` ` '\`•
\.\ ,1/Quarter.• `_'•,
Composite 2
E
Total Phosphorus
�,\
'\\
:• i./QuaiteF `•�
Composite 2
E
Acute Toxicity'
'
\'\ ,-,�
` 1/ uarter
.� Q '`•„•
2
Composite
E
Dissolved Oxygen 6
% '�•_, \ \\`
'ariablej
Grab
U & D
Temperature (°C) 6
<\ ,ice
\�
Variable
Grab
U & D
Conductivity 6 ;-\
•
`\. `,
\\\ \
\\\ Variable 7
Grab
U & D
Footnotes:
1 E = Effluent; I = Influent;.ii-=‘ upsti eaq2 mi "from'0utfall. D `downstream, 100 yards upstream of Lock and Dam #3.
2. Composite samples rr�u'st be -refrigerated..;'•,.
3
Total Residual Chlorine\(TRC)\=,the`Perm tee 4•141,continue to report all values recorded using North Carolina -
certified field andlab. test ethods. However, becua,low-level TRC is difficult to quantify in a wastewater matrix,
the Division•s�iall. considermali `eefflue it values‘reported-below 50. µg/L to be compliant.
4 Effluent dissolv`l oxygem(DO) shall not fall`below 5'rng/L. The Permittee shall collect effluent DO samples from the
box combining effluents ofOutfalls 001"aid. 00t
5 Whole Effluent To' icity (WE'T)`tsgng; acuteoxicity P/F at 90% using Fathead Minnow. WET tests shall be
conducted in Februa'ry;..May,'August and November [See Part A. (2.)]. The Permittee shall collect toxicity samples
from the box combining•effluents of Outfalls 001 and 002.
6 Receiving•Stream Moniforing.2 As a member of the Middle Cape Fear River Basin Association, the Permittee's
instream monitoring respongillitie's are hereby waived by Memorandum of Agreement. However, should this
membership terminate for any reason, the Permittee shall notify the Division immediately, and the Permittee shall
immediately resume instream monitoring requirements, as specified herein.
7 Variable Sampling — the Permittee shall collect receiving -stream samples 3/Week during the summer months ofJune
through September and 1/week for the remaining months of the year.
The Permittee shall add no chromium, zinc, or copper to the treatment system except as pre -approved additives
to biocide compounds or those resulting from the normal degradation of process piping or equipment. The
Permittee shall discharge no floating solids or foam visible in other than trace amounts.
Additional effluent limitations and monitoring requirements apply to this permit [see additional tables,
Part A. (1.) continued, and Parts A. (2.) through A. (4.) regarding abandoning discharge].

Permit NC0003 719
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Continued)
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from Outfall 002. Such discharges shall be limited and monitored by the Permittee for
OCPSF parameters, as specified below:
Effluent
Characteristics
Limits
Monitoring
Requirements
DAILY .'
•:
.MONTHLY
: AVERAGE
.(pounds/day)
Measurement
Measurement
Frequency
Sample
Type
Sample
Location
Acenaphthene
0.112
0.042
1/Year
Grab
Effluent
Acenaphthylene
. 0.112
0.042
1/Year _
Grab
Effluent
Acrylonitrile
0.460.
0.183
1/Year
Grab,
Effluent
Anthracene
0.112
0.042
1/Year
Grab•:``-,.
Effluent
Benzene
0.259
, 0.070
1/Year
'. Grab \\
•,\ Effluent
Benzo(a)anthracene
0.112
0.042
1/Year . .
`Grab\
\Effluent .
3,4-Benzofluoranthene
0.116 ,
0.044
\/Year
. Grabs
Effluent
Benzo(k)fluoranthene
0.112
0.042
1/Year-
-;'.Grab\,.
> "Effluent
Benzo(a)pyrene
0.116
0.044
' /Year, - '
,. `Grab'. `'
,Effluent'`
Bis(2-ethylhexyl) phthalate
0.531
0.196 ,
, "1/Year, `. "
:'Grab\ "•.
\ Effluent;.`'- `
Carbon Tetrachloride
0.072
0.034 `
\` , 1/Year ..\
. Graili ',\
\\Effluent
Chlorobenzene
0.053
0.029,•;
., ..,1/Year_
, ',..Grab`,,
'',, •Effluent
Chloroethane
0.510
<'`0.198
\S/Year- '
..... Grab
''' Effluent
Chloroform
0.087
r ' .040,::\\
1/Year
";Grab)
Effluent
2-Chlorophenol
0.186 K.
,/ 0.059 \\
1/Yeaf`."
Grab
Effluent
Chrysene
rY
O_ .1.12. "\
•�\ 0.042 .'-
_'`,. 1/Year',;\..•
Grab
Effluent
Di-n-butyl phthalate
0.1b8 N
\\...9.0sr>
''\ .,1/Year
Grab
Effluent
1,2-Dichlorobenzene
.---4.310.`\•.`•,,
' Q.1.46
`;Wear
Grab
Effluent
1,3-Dichlorobenzene {
/' ''0 084 \\
',, \... 0:059
11Year
Grab
Effluent
1,4-Dichlorobenzene_ \'\
0.05s3 \`\,;>
0;029•, ;
1/Year
Grab
Effluent
1,1-Dichloroethane' ,. `.\
\\\ 0.1,1.2i
\ ,,/ 0.042\N\
1/Year
Grab
Effluent
1,2-Dichloroetharie,•`-
NN6.401`�
\\ 0.129 \.i
1/Year
Grab
Effluent
1,1-Dichloroethylene'\ •.\
\\\Thg4 �N'N
\..'0,030
1/Year
Grab
Effluent
1,2-trans-Dichloroethyleii
. \ hI03\
, 1040
1/Year
Grab
Effluent
2,4-Dichlorophenol 'ti,
., 0413 `�\.
0.074
1/Year
Grab
Effluent
1,2-Dichloropropane
',X 0.437 '''
0.291
1/Year
Grab
Effluent
1,3-Dichloropropylene
\:"0.084
0.055
1/Year
Grab
Effluent
Diethyl phthalate
'0386
0.154
1/Year
Grab .
Effluent
2,4-Dimethylphenol
0.068
0.034
1/Year
Grab
Effluent
Dimethyl phthalate
0.089
0.036
1/Year
Grab
Effluent
4,6-Dinitro-o-cresol
0.527
0.148
1/Year
Grab
Effluent
2,4-Dinitrophenol
0.234
0.135
1/Year
Grab
Effluent
2,4-Dinitrotoluene
0.542
0.215
1/Year
Grab
Effluent
Ethylbenzene
0.205
0.061
1/Year
Grab
Effluent
Fluoranthene
0.129
0.048
1/Year
Grab
Effluent
Fluorene
0.112
0.042
1/Year
Grab
Effluent
[Part A. (1.) continues on next page]
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

Permit NC0003719
OCPSF - Continued
•':. Effluent
Characteristics
Limits
: Monitoring Requirements
141 .Y' '
MAXIMUM
(pounds/day) .
`•MON rigY=
AVERAGE -
(pounds/day)`
=Measurement' `=
,..:,. .1. ,.;,! .
Frequcy ' -
' Sa''''' .
_ ....
:. Type `
.. Sample.
:Location
Hexachlorobutadiene
0.093
0.038
1/Year
Grab
Effluent
Hexachloroethane
0.103
0.040
1/Year
Grab
Effluent
Methyl Chloride
0.361
0.164
1/Year
Grab
Effluent
Methylene Chloride
0.169
0.076
1/Year
Grab
Effluent
Naphthalene
0.112
0.042
1/Year
Grab
Effluent
Nitrobenzene
0.129
0.051
1/Year
Grab
Effluent
2-Nitrophenol
0.131
0.078
1/Year
Grab
Effluent
4-Nitrophenol
0.236
0.137
1/Year
Grab.,
Effluent
Phenanthrene
0.112
0.042
1/Year
Grab\'`
Effluent
Phenol
0.049
0.029
1/Year
; . Grab `
\\. Effluent
.,,Effluent
Pyrene
0.127
0.048
1/Year <\,
'Qrali-\
Tetrachloroethylene
0.106
0.042
1/YeAr \`.•
Q"rall\
\ Effluent
Toluene
0.152
0.049
• l eal
\'•Grab\
Effluent ,
1,2,4-Trichlorobenzene
0.266
0.129
/N1lYear\\\<N.
\Grab \'
" /Effluent'
1,1,1-Trichloroethane
0.103
0.040
,. f1'/Ye"ar\ \\;
,:^C`rab, ',`\,
Effluents`-`
1,1,2-Trichloroethane
0.103
0.040
\\ 1/Year\\ '\_\
Grab\\
Effluent -
Trichloroethylene
0.103
0.040/ \
\;\1/Year., \\
\`Grab-N,
\'Effluent
Vinyl Chloride
0.510
0,198 7
\17Y'ear) .,`
\ 'Grab
''.','Effluent
/'_`•;✓ \
:Effluent<
Clia ac r ter' •tic is s:.
_
Limits'
-
_ ,, .'.=. =
�.lYlonitorin
�F <_::',
- .
-
- - ....
D`
DAILY
•MAXIIVIUIVI"
ounds/da
(P _ y
: except as. noted)`
1VI0 <HI�Y- '
AVERAE' '
ounds/da`
- .(P Y=
:except` as "noted)'
i`i .ti :..;
, -
1Vleasurement>
'Fre'uenct
; ° .
..,,
;�':F :-,;':
-`Sam 1e; .
P
e.
-
'
,-tSam�'1e:•
P,
�1✓oca"ton.
. ,_
2,6-Dinitrotoluene1'
-\4.?.'0 ag/L ,
j 0�48,{(glL\\'
,/ 1/Quarter
Grab
Effluent
Hexachlorobenzerie;1,
1`•6'F10 z
'.0.03\µg/L \.'
1/Quarter
Grab
Effluent
Total Chromium \
\. 53 \., \\
N 2A\
1/Quarter
Grab
Effluent
Total Copper
\ \\ 6.4 \"\ \'•,
'2:8Y
1/Quarter
Grab
Effluent
Cyanide 2
\•\`•.2.3 `..�.
\\ 0.8
1/Quarter
Grab
Effluent
Total Lead
\1.3, _ ' !
0.6
1/Quarter
Grab
Effluent
Total Nickel
3.2
1/Quarter.
Grab
Effluent
Total Zinc
5.0 '
2.0 -
1/Quarter
Grab
Effluent
Footnotes:
1. Water -quality based limit expressed in micrograms per liter (µg/L).
2. Cyanide - Due to difficulties quantifying cyanide in a wastewater matrix, the Division shall
consider all cyanide values reported below 19 Ibs/day (the mass equivalent of 10 µg/L at
0.228 MGD) to be "compliant" with this permit. However, the Permittee shall submit all
valid values reported by a North Carolina -certified laboratory, and the Permittee shall use
these valid values to calculate required averages, if any, even if values fall below 10 Kg/L.

PermitNC0003719
A. (2.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The Permittee shall conduct acute toxicity tests 1/Quarter using protocols defined in the North Carolina
Procedure Document entitled "Pass/Fail Methodology for Determining Acute Toxicity in a Single Effluent
Concentration" (Revised July, 1992 or subsequent versions). The monitoring shall be performed as a Fathead
Minnow (Pimephales promelas) 24-hour static test. The effluent concentration, at which there may be at no time
significant acute mortality, is 90% (defined as treatment two in the procedure document). Effluent samples for
self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment.
The tests will be performed during the months of February, May, August, and November.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE6C.
Additionally, DWQ Form AT-2 (original) is to be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, N.C. 27699-1621 ,`�
Completed Aquatic Toxicity Test Forms shall be filed with the-,Eiivironmental Sciences Branch no -later than 30
days after the end of the reporting period for which the reportis-made -. `� :` `\'� /
Test data shall be complete and accurate and include all.supporting chemicaUph s cal easurethents performed
in association with the toxicity tests, as well as alldose/response data:,Tottal\.residual`chlorine of the effluent
toxicity sample must be measured and reportedif chlorine is:employed`for.. disinfectionf the waste stream.
Should there be no discharge of flow frourthe.facih y during a month in which toxicity monitoring is required,
the Permittee will complete the informq bn4ocated at;the top of the,aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe numbei,,county, and tlke month/year of the report with the.notation of "No
Flow" in the comment area of the form. Threpor`tshall be-•submitted•td•the Environmental Sciences Branch at
the address cited above. \`� \ ' f \ \
,\ d\ \'
Should any single quarterly in itoiing`i d icate�a failure tdineet specified limits, then monthly
monitoring will be in immediately until such time.that a single test is passed. Upon passing, this monthly
test requirement will revert\to quarterly in the.m.onths specified above.
Should the Permittee fail to .• `o for during.aj onth in which toxicity monitoring is required, then monthly
\\ , \\ `.\m\
monitoring will begin\irkmedia�ely\uutil sucli time that a single test is passed. Upon passing, this monthly test
requirement will revert`to\�quarte1ly i `the months specified above.
\`\ i \ >.
Should any test data from either hese monitoring requirements or tests performed by the North Carolina Division
of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
follow-up testing to be completed no later than the last day of the month following the month of the initial
monitoring.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
follow-up testing to be completed no later than the last day of the month following the month of the initial
monitoring.

Permit NC0003719
A. (3.) BIOCIDE APPROVAL
The Permittee shall obtain approval from the Division's Aquatic Toxicology Unit prior to discharging any
biocide (not previously approved by the Division) under this permit. Approval for use of any biocide -not
previously The Permittee shall request approval of any new unauthorized biocide at least 90 days in advance of
planned usage.
Contact the Aquatic Toxicology Unit for detailed instructions on requesting biocide approval:
NC DENR / DWQ / Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Concentrations of chromium, copper, or zinc added to biocides shall not exceed.applicable water quality
standards or action levels in the receiving stream.
\' • ,. \\ `•
A. (4.) LABORATORY TEST -METHOD QUANTITVI\OT.LE,VET;S `AND COIVIPIIANCE
. \�.•
For any given parameter, the Permittee must apply a state -certified ana1y ical'•test method with; a'� practical
quantitation level (PQL) at or below the NPDES permit limit. If suchhl'eyel: of analytical sensitivity is not
technologically feasible, the Permittee shall employ:a statecertifed analytical mefhod��with the lowest available
test -method PQL, and values reported as "not'deteeted" by this'7oyest ailq e PQL shall be deemed
"compliant" with this permit. `''
\` \N ` ` < \\\
A. (5.) PLASTICS RECYCLING;FACILITY (PRF) - WASTE CHARACTERIZATION
:. < \. ,• \.,.,`
Although PRF,eon ruction.,doe,,s not requ;reanrlTPDES Authorization to Construct (ATC) Permit, an
ATC permit is `r0\.uired\tor\aiy acl?ditorial4reatment units or processes necessary to treat PRF wastes.
\\ \, \ ``* \ \
Therefore, during construction\ci t}\ie proposed PRF (flow estimated at 0.111 MGD), -DAK shall locate
and designate internal''PRF O0fa11.,001, a sampling location influent to the onsite WWTP, whereby the
Permittee may sample and'•analye PRF wastes prior to mixing with other wastes. No later than 90 days
prior to receiving PRF wastes atthe onsite WWTP, DAK shall provide a written report anticipating the
character of PRF wastes generated under SIC 5162 to include:
1. waste chemical character and methods used to identify, quantify and characterize wastes
2. waste treatability by existing onsite WWTP processes
3. examples and character of wastestreams from similar active/operating SIC 5162 PRFs
4. any anticipated interference by PRF wastes with existing wastestream treatability
5. any new treatment units identified or processes requiring ATC
The Division reserves the right to reopen this permit to include additional treatment and/or monitoring
based on a satisfactory waste characterization.

City of Fayetteville, North Carolina
Permit
To Discharge Wastewater Under the Public Works Commission's
Industrial Pretreatment Program
In compliance with'the provisions of the Fayetteville City Code, North Carolina General Statute 143-215.11,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the City of Fayetteville.
DAK Americas, LLC
is hereby authorized to discharge wastewater from a facility located at
3216 Cedar Creek Road
Fayetteville, North Carolina
Cumberland County
into the City of Fayetteville's municipal sanitary sewer system and municipal wastewater treatment facility
located at:
Rockfish Water Reclamation Facility
NPDES No. NC0050105
2536 Tracy Hall Rd
Cumberland County
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in parts I,
II, and III hereof.
This permit shall become effective on January 1, 2009.
This permit and the authorization to discharge shall expire at midnight on December 31, 2013.
Signed this day of , 2008.
Permit Number 2116RF
40 CFR Category 414
Steven K. Blanchard, General Manager
Public Works Commission
City of Fayetteville
North Carolina

IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40, CFR#: 414
Supplement toPermitCover Sheet
DAK Americas, LLC
is hereby authorized to:"
1. Continue operation of the existing pretreatment facility, consisting of the
following methods of treatment:
DAK Sanitary waste sump, 2 DAK Process waste sumps, Comniinutor Pit, Existing
Lift Station, Sample Point, 2 EQ Tanks, Emergency Spill Basins, pH Adjustment Pit,
Aeration Basins, Clarifier, Digester, Contact Chamber,' and New Lift Station
pumping to PWC lift station
2. After receiving Authorization to Construct from the Public Works
Commission, construct and operate pretreatment units as needed to
meet final effluent limitations as set forth in this permit.
3. Discharge from said pretreatment works facility into the Public
Works Commission's Rockfish Water Reclamation Facility, NPDES
#NC0050105 Highway 87 South Cumberland County.
2

DAK Americas LLC
Permit Outline
PART I. Effluent Limitations and Monitoring Requirements
A. 1 Description of Discharge
2. Location of Monitoring Point
3. Permit Modification History
B. Effluent Limits and Monitoring Requirements
C. Monitoring and Reporting
PART II. General Permit Conditions
PART III. Special Permit Conditions
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#:.414
3

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
A. 1. Description of Discharge(s)
Pipe Number 002 Description of Discharge
Discharge of domestic and industrial wastes as well as affectedstormwater being
recovered from the site. This includes process and non -process wastewater from
DAK Resins, LLC and DuPont Teijin Films as listed below.
DAK Resins: Discharge includes all flows regulated under 40 CFR Part 414 - the
Organic Chemicals, Plastics, and Synthetic Fibers Category (Equipment/facility
washdown, process reaction water, stormwater, and condensate) as well as
boiler/cooling tower blowdown and domestic wastewater.
DuPont Teij in Films: Discharge includes all flows regulated under 40 CFR Part 414 -
the Organic Chemicals, Plastics, and . Synthetic Fibers Category (process water,
washdown water, steam condensate, stormwater) as well as Domestic wastewater.
2. Location of Monitoring Point.
Monitoring point is behind the clarifier where DAK has a sampler permanently set
in place.
Cape Fear River
;DAK pump
station to
PWC
Sampling Point
Clarifier
4

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Americas, LLC
Permit#:2116RF
Pipe#: 01
40 CFR#: 414
3. DAK AMERICAS, LLC Permit Modification History.
A. Original Permit issued on May 1, 2006 expires June 30, 2008.
B,. March 1, 2007, permit modification issued to monitor CBOD instead of BOD
due to long term monitoring requirements, changes were made to allow electronic
submittal of reports, and the pH was changed to allow a variance of 6.0 to 11.5
standard units.
C. January 1, 2009, permit renewal, lead monitoring was changed from once every
six months to quarterly, flow limit was reduced from .250 MGD to .075 MGD,
CBOD and TSS limits were reduced from 100 mg/L to 25 mg/L, various general
permit conditions were modified to comply with state requirements, and limited
detection levels were added for long term monitoring requirements.
5

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. B.1.EFFLUENT LIMITS AND MONITORING REQUIREMENTS
1. Receiving POTW Name: Rockfish Creek Water Reclamation Facility
Receiving POTW NPDES#: NC0050 105
Effective Date for These Limits: Effective Date of this Permit
Expiration Date for These Limits: Expiration date of this Permit
Pipe #: 002 - Regulated (OCPSF) under 40 CFR 414.
This discharge shall be limited and monitored as specified below. •Pollutants and
prohibitions not regulated or enumerated below shall be discharged in accordance with the
City of Fayetteville's Sewer Use Ordinance. Data collected for NPDES DMR compliance
may also be submitted to PWC and will be accepted for compliance judgment in lieu of
separate sample collection for pretreatment permit requirements.
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38.7
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1/6 Months
1/ Calendar Year
Anthracene
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
Benzene
110.4
46.9
Grab
1/6 Months
1/ Calendar Year
Bis phthalate
212.59
78.3
Grab •
1/6 Months
1/ Calendar Year
Carbon tetrachloride
312.12
117
Grab
1/6 Months
1/ CalendarYear
Chlorobenzene
313.1
117.0
Grab
1/6 Months
1/ CalendarYear
Chloroethane
243.1
90.6
Grab
1/6 Months
1/ Calendar Year
Chloroform
267.8
91.5
Grab
1/6 Months
1/ Calendar Year
Di-n-butyl phthalate
. 35.4
16.5
Grab
1/6 Months
1/ Calendar Year
1,2 dichlorobenzene
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
1,3-dichlorobenzene
313.1
117.0
Grab
1/6 Months
1/ CalendarYear
1,4-dichorobenzene
313.1
117.0
Grab
1/6 Months
1/ Calendar Year
1,1, DCA
48.6
18.1
Grab
1/6 Months
1/ CalendarYear
1,2 DCA
473.0
148.3
Grab
1/6 Months
1/ Calendar Year
1,1 DCE
49.4
18.1
Grab
1/6 Months
1/ CalendarYear
1,2 trans DCE
54.4
20.6
Grab
1/6 Months
1/ Calendar Year
1,2 Dichloropropane
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
1,3 Dichloropropylehe
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
Diethyl phthalate
93.1 .
. 37.9
Grab
1/6 Months
1/ Calendar Year
Dimethly phthalate
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
4,6 Dinitro-o cresol
228.2
64.3
Grab
1/6 Months
1/ Calendar Year
Ethylbenzene
313.1
117.0
Grab
1/6 Months
1/ CalendarYear
'Fluoranthene
44.5
.18.1
Grab
1/6 Months
1/ CalendarYear
Fluorene
38.7 .
15.7
Grab
1/6 Months
1/ Calendar Year
Hexachlorobenzene
89.1
89.1
Grab
1/6 Months
1/ Calendar Year
Hexachlorobutadiene
313.1
117.0
Grab
1/6 Months
1/ Calendar Year
hexachloroethane
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
6

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Americas, LLC
Pe rmit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. B.1.EFFLUENT LIMITS AND MONITORING REQUIREMENTS
1. Pipe#: 002- Regulated (OCPSF) under.4
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Methyl chloride
243.1
90.6
Grab
1/6 Months
1/CalendarYear
Methylene chloride
140.1
29.7
Grab
1/6 Months
1/ Calendar Year
Naphthalene.
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
Nitrobenzene
5275.2
1843.3
Grab .
1/6 Months
1/ Calendar Year
2-Nitrophenol
190.3
53.6
Grab
1/6 Months
1/ Calendar Year
4-Nitrophenol
474.6
133.5
Grab
1/6 Months
1/ Calendar Year
Phenanthrene
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
Pyrene
39.6
16.5
Grab:
1/6 Months
1/ Calendar Year
Tetrachloroethylene
135.1
42.8
Grab.
1/6 Months
1/ Calendar Year
Toluene
61.0
23.1
Grab
1/6 Months
1/ Calendar Year
Total Cyanide
988.8
346.1
Grab
1/6 Months
1/ Calendar Year
Total Lead
568.6
263.7
Grab
1/6 Months
1/ Calendar Year
Total Zinc
2150.6
865.2
Grab
1/6 Months
1/ Calendar Year
1,2,4 Trichlorobenzene
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
1,1,1 TCA
48.6
18.1
Grab
1/6 Months
1/ Calendar Year"
1,1,2 TCA
104.6
26:4
Grab
1/6 Months
1/ Calendar Year
TCE
56.9
21.4
Grab
1/6 Months
1/ Calendar Year
Vinyl chloride
141.7
79.9'
. Grab
1/6 Months
1/ Calendar Year
7

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. B.2.EFFLUENT LIMITS AND MONITORING REQUIREMENTS
2. Receiving POTW Name: Rockfish Creek Water Reclamation Facility
Receiving POTW NPDES#: NC0050105
Effective Date for These Limits: Effective Date of this Permit
Expiration Date for These Limits: Expiration Date of this Permit
Pipe #: 002 - Regulated (OCPSF) under 40 CFR 414
This discharge shall be limited and monitored as specified below. Pollutants and
prohibitions not regulated or enumerated below shall be discharged in accordance with the
City of Fayetteville's Sewer Use Ordinance. Data collected for NPDES DMR compliance
may also be submitted to PWC and will be accepted for compliance judgment in lieu of
separate sample collection for pretreatment permit requirements.
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Flow
.075 MGD
Metered (*2)
daily
CBOD
25 mg/1
Composite
2
1/month
1/6 months
TSS
25 mg/I
Composite
2
1/ month
1/6 months
Ammonia
*3
Composite
0.1
1/ month
1/6 months
Oil & Grease
250
Grab
1/3 months
1/6 months
Total Phos.
.*3
Composite
1/3 month
1/6 months
Arsenic
*3
Composite
0.01
1/3 month
1/6 months
Cadmium
*3
Composite
0.001
1/3 month
1/6 months
Chromium
*3
Composite
0.005
1/3 month
1/6 months
Copper
*3
Composite
0.002
1/3 month
1/6 months
Cyanide
*3
Grab
0.005
1/3 month
1/6 months
Lead .
*3
Composite
0.002
1/3 month
1/6 months
Mercury
*3
Composite
0.0002
1/3 month
1/6 months
Molybdenum
*3
Composite
0.1
1/3 month
1/6 months
Nickel
*3
Composite
0.01
1/3 month
1/6 months
Selenium
*3
Composite
0.01
1/3 month
1/6 months
Silver
*3
Composite.
0.005
1/3 month
.
1/6 months
Zinc
*3
Composite
0.01
1/3 month
1/6 months
Phenol
*3
Grab
1/3 month
1/6 months
Bromoform
*3
Composite
1/3 week
1/6 months
Xylene
*3
Composite
1/3 month
1/6 months
Antimony
*3
Composite
1/3 month
1/6 months
pH
* 1
Grab
1/ month
1/6 months
See Page 9 for Limit Page Notes and Page 11 for Definitions.
8

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
Limits Page Notes:
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
* 1 The pH shall not be less than 6.0 or greater than 11.5 standard units. pH will be
determined by field analysis on a grab sample of final effluent.
*2 Flow measurement: See Part III. Special Condition D. for additional requirements.
* 3 Monitoring requirement only. If monitoring results indicate the presence of pollutants
in amounts that could cause endangerment, upset, pass -through, or hinder the
operation of the collection system or the treatment facility in any way, pollutant
specific limits may be applied.
*4 Self -monitoring requirements shall become effective the effective date of this permit.
Daily means once a day, 1/week means once a week, 1/month means once a month,
1/3 means once January -March, once April -June, once July -September, and once
October -December, 1/6 months means once January -June and once July -December of
each year.
*5. Detection limits for each parameter shall be at least as low as outlined in the chart.
9

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS.
C. Monitoring and Reporting
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#:. 01
40 CFR#: 414
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the
volume and nature of the monitored discharge. All samples shall be taken at the
monitoring points specified in this permit and, unless otherwise specified.
Monitoring points shall not be changed without notification to, and approval by, the
PWC.
Self -Monitoring and/or Additional Monitoring
If the permittee, is required to self -monitor by this permit, using EPA approved
analytical methods, the results of such monitoring shall be submitted to the PWC's
Pretreatment Program Office on or before the tenth of the month following sample
collection. The PWC may require more frequent monitoring, or the monitoring of
additional pollutants not required in this permit, by written notification.
If the sampling performed by the permittee indicates a violation, the permittee shall
notify the PWC within 24 hours of becoming aware of the violation. The permittee
shall also repeat the sampling and analysis and submit the results of the repeat
analysis to the PWC within 30 days after becoming. aware of the violation.
3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with
the techniques prescribed in 40 CFR Part 136 (U.S. Environmental Protection
Agency), and amendments thereto unless specified otherwise in the monitoring
conditions of this permit.
4. Certified Laboratory Analysis
Pollutant analysis shall be performed by a North Carolina Department of
Environmental and Natural Resources Certified Laboratory that is certified in the
analysis of the particular pollutant in wastewater.
10

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
5. Reporting
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
If the permittee monitors any pollutant at the 'location(s) designated herein more
frequently than required by this permit, using approved analytical methods as
specified above, the results of such monitoring shall be submitted to PWC.
Monitoring results obtained by the permittee and all other reports required herein
shall be submitted to the PWC at the following address:
System Protection Supervisor
Public Works Commission
Post Office Drawer 1089 •
Fayetteville, North Carolina 28302
6. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit,
the permittee shall record the following data:
A. The exact place, date, and time of sampling,
B. The date(s) the analyses were performed; and
C. The person(s) or approved laboratory that performed the analysis.
7. Definitions
A. A composite sample, for monitoring requirements, is defined as the automatic
or manual collection of one grab sample of constant volume, not less than
100 ml, collected every hour during the entire discharge period on the
sampling day. Sampling day shall be atypical production and discharge day.
B. A grab sample, for monitoring requirements, is defined as a single "dip and
take" sample collected at a representative point in the discharge stream.
C. A daily monitoring frequency shall mean each working day.
11

PART II. • IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
Part II. GENERAL PERMIT CONDITIONS
A. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit non-
compliance constitutes a violation of the City of Fayetteville Sewer Use Ordinance
and is grounds for possible enforcement action(s).
B. Duty to Mitigate - Prevention of Adverse Impact
The permittee must take all reasonable steps to minimize or prevent any discharge in
violation of this permit which has a reasonable likelihood of adversely affecting
human health, the POTW's discharge, the water receiving the POTW's discharge, or
the environment.
Facilities Operation, Bypass
The permittee shall, at all times, maintain in good working order, and operate as
efficiently as possible, 'all control facilities or systems installed or used to achieve
compliance with the terms and conditions of this permit. By-pass of treatment
facilities is prohibited except as provided for and in accordance with the requirements
set forth by this permit. By-pass approval shall be given only when such by-pass is in
compliance with 40 CFR 403.17.
D. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of
treatment or control of wastewaters shall be disposed of in a manner such as to
prevent any pollutants from such materials from entering the sewer system. The
permittee is responsible for assuring its compliance with any requirements regarding
the generation, treatment, storage, and/or ultimate disposal of "Hazardous Waste" as
defined under the Federal Resource and Recovery Act (RCRA). The permittee shall
identify, to the PWC the hazardous/toxic waste hauler used for removal of such
substances and notify the PWC of any changeof said hauler.
12

PART II. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
E. Upset Conditions
An "upset" means an exceptional incident in which there is an unintentional and
temporary non-compliance with the effluent limitations of this permit because of
factors beyond the reasonable control of the permittee. An upset does not include
non-compliance to the extent caused by operational error, improperly designed or
inadequate treatment facilities, lack of preventative maintenance, or careless and/or
improper operations.
An upset may constitute an affirmative defense for actions brought for the non-
compliance. The permittee .has the burden of proof toprovide evidence and
demonstrate that none of the factors specifically. listed above were responsible for the
non-compliance.
F. Right of Entry
The permittee shall allow the staff of the State of North Carolina Department of
Environment, Health, and Natural Resources, Division of Environmental
Management, the Regional Administrator of the Environmental Protection Agency,
the City of Fayetteville, the Public Works Commission, and/or their authorized
representatives, upon the presentation of credentials:
1. To enter upon the permittee's premises where a real or potential discharge is
located or in which records are required to be kept under the terms and
conditions of this permit; and
2. At reasonable times to have access to and copy records required to be kept
under the terms and conditions of this permit; to inspect any monitoring
equipment or monitoring method required in this permit, and to sample any
discharge of pollutants.,
G. Availability of Reports and Records/Record Retention
The.. permittee shall retain records of all monitoring information, including all
calibration and maintenance records as well as copies of reports and information used
to complete the application for this permit for at least three years. All records that
pertain to matters that are subject to any type of enforcement action shall be retained
and preserved by the permittee until all enforcement activities have concluded and all
periods of limitation with respect to any and all appeals have expired. These records
include, but -are not limited to, production records, wastewater self -monitoring
records, and State and Federal EPA required records.
13

PART II. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
Except for data determined to be confidential under the City of Fayetteville's Sewer
Use Ordinance, Division 7, all reports prepared in accordance with terms of this
permit shall be available for public inspection through the office of the Public Works
Commission of the City of Fayetteville. As required by the Sewer Use Ordinance,
effluent data shall not be considered confidential.
H. Duty to Provide Information
The permittee shall furnish to the Manager of the Public Works Commission or his
designee, or the Division of Environmental Management, within a reasonable time,
any information which the above parties may request to determine whether cause
exists for modifying, revoking and re -issuing, or terminating this permit or to
determine its compliance with this permit. The permittee shall also furnish, upon
request, copies of records to be kept by this permit.
I. Signatory Requirements
All reports or information submitted pursuant to the requirements of this permit
must be signed and certified by the Authorized Representative as defined under
the Sewer Use Ordinance. If the designation of an Authorized Representative is
no longer accurate because a different individual or position has responsibility for
the overall operation of the facility, or overall responsibility for environmental
matters for the company, a new authorization satisfying the requirements of this
section must be submitted to the PWC System Protection Supervisor prior to or
together with any reports to be signed by an authorized representative.
J. Toxic Pollutants
If a toxic effluent standard or prohibition (including any schedule of compliance
specified in such effluent standard or prohibition) is established under Section 307(a)
of the Federal Clean Water Act for a toxic pollutant which is present in the discharge,
and such standard or prohibition is more stringent than any limitation for such
pollutant in this permit, this permit may be revised or modified in accordance with
the toxic effluent standard or prohibition and the. permittee so notified.
K. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or
criminal penalties for non-compliance.
14

PART II. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
L. Federal and/or State Laws
Nothing in this permit shall be construed to preclude the institution of any legal
action 'or relieve the permittee from any responsibilities, liabilities, or penalties
established pursuant to any applicable Federal and/or State Laws or regulations.
M. Penalties for Violation of Permit Conditions
The City of Fayetteville Sewer Use Ordinance provides that any person who violates
a permit condition is subject to a civil penalty not to exceed $25,000.00 per day of
such violation, with each day deemed as a separate violation.
N. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in any enforcement action that it would have
been necessary to halt or reduce the permitted activity to maintain compliance with
the conditions of this permit.
O. Penalties for Falsification of Reports
The City of Fayetteville Sewer Use Ordinance and North Carolina General Statute
143-215 provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required
to be maintained under this permit, including monitoring reports or reports of
compliance or non-compliance shall, upon conviction, be punished by a fine, or by
imprisonment for not morethan six (6) months, or by both.
P. Transfer of Discharge Permit
Q.
Wastewater discharge permits are issued to specific industrial users for specific
operations. Wastewater discharge permission shall not be re -assigned or transferred
or sold to a new owner, new user, different premises, or a new or changed operation.
Property Rights
This permit does not convey any property rights in either real or personal property, or
any exclusive privileges, nor does it authorize any injury to private property or any
.invasion of personal rights, nor any infringement of Federal, State or City laws or
regulations.
15

PART II. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
R. Severability
The provisions of this permit are severable and, if any provision of this permit or the
application of any provision of this permit to any circumstance is held invalid, the
application of such provision to other circumstances and the remainder of this permit
shall not be affected thereby.
S. Permit Modification, Revocation, Termination
This permit may be modified, revoked and re -issued or terminated with cause in
accordance to the requirements of the City of Fayetteville Sewer Use Ordinance and
North Carolina General Statute or implementing regulations.
T. Re -Application for Permit Renewal
The Permittee is responsible for filing an application with the PWC for re -issuance of
this Permit 180 days prior to the expiration date of this Permit.
U. Dilution Prohibition
The permittee shall not increase the use of potable or process water or in any way
attempt to dilute the discharge as a partial or complete substitute for adequate
treatment to achieve compliance with the limitations contained in this permit.
V. Notification of Production Changes
The permittee shall give notice to the PWC at least 90 days prior to any facility
expansion, production increase, or process modification which has the potential to.
result in new or substantially increased discharges or a. change in the nature of the
• discharge.
W. Construction
No construction of pretreatment facilities or additions thereto shall commence until
Final Plans/Specifications have been submitted to the PWC's Pretreatment Program
Staff and written approvaland an Authorization to Construct have been issued by the
PWC.
X. Sludge Management Plan
Within 90 days prior to the initial .disposal of sludge generated by any pretreatment
facility, the permittee shall submit a sludge management plan to the PWC's
Pretreatment Program Office.
16

PART II. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 'CFR#: 414
Y. Re -Opener
This permit shall be modified or, alternatively, revoked and reissued to comply with
any applicable effluent standards or limitation issued or approved by the City, as the
Control Authority, for the control of any pollutant not now controlled by this permit
or the City Ordinance.
Z. Categorical Standard Re -Opener
This permit shall be modified, or alternatively, revoked and reissued, to comply with
any applicable effluent standard or limitation issued or approved under Sections
302(b) (2) (c), and (d), 304(b) (2), and 307(a) (2) of the Clean Water Act, if the
standard or limitation so issued or approved:
1. Contains different conditions or is otherwise more stringent than any effluent
limitation in this permit, or
2. Controls any pollutant not limited in this permit.
The permit as modified or reissued under this paragraph shall also contain any other
applicable requirements of the Act.
AA. Reports of Potential Problems
The permittee will provide protection from accidental and slug loading discharges.
The permittee is responsible for contacting the PWC by telephone immediately of all
discharges that could cause problems to the POTW, including any slug loadings as
defined by 40 CFR 403.5(b). If the permittee experiences such a discharge, they shall
inform PWC immediately upon the first awareness of the commencement of the
discharge. Notification shall include location of the discharge, type of waste,
concentration and volume, if known, and corrective actions taken by the permittee to
prevent future discharges. The permittee shall, within five (5) days of the verbal
notification, submit to the PWC Pretreatment Program Office a detailed written
report describingthecause of the discharge; and those measures taken to prevent
similar future occurrences. Such notification shall not relieve the permittee from any
liability that may be incurred as a result of the discharge (see Sewer Use Ordinance,
Section 28-129).
BB. General Prohibitive Discharge
The permittee shall comply with the general prohibition discharge standards in 40
CFR 403.5 (a) of the Federal pretreatment regulations.
17

PART.II. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
CC. Specific Prohibitions
The permittee shall not allow wastewater to be discharged to the Municipal Sewer
System that exhibit the following characteristics, as set forth in 40 CFR 403.5(b):
1. Pollutants which create a fire or explosion hazard in the POTW, including but
not limited to, wastestreams with a closed cup flashpoint of less than 140
degrees Fahrenheit or 60 degrees Celsius using the test methods specified in
40 CFR 261.21.
2. Pollutants which will cause corrosive structural damage to the POTW, but in
no case discharges with pH lower than 6.0, unless the works is specifically
designed to accommodate such discharges.
3. Solid or viscous pollutants in amounts which will cause obstruction to the
flow in the POTW resulting in interference.
4. Any pollutant, including oxygen demanding pollutants (BOD, etc.) released •
in a discharge at a flow rate and/or pollutant concentration which will cause
interference with the POTW.
5. Heat in amounts that will inhibit biological activity in the POTW resulting in
interference, but in no case heat in such quantities that the temperature at the
POTW treatment plant exceeds 104 degrees Fahrenheit or 40 degrees Celsius
unless the PWC approves alternate temperature limits.
6. Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin
in amounts that will cause interference or pass through.
7. Pollutants which result in the presence of toxic gases, vapors, or fumes within
the POTW in a quantity that may cause acute worker health and safety •
problems.
8. Any trucked or hauled pollutants, except at discharge points designed by
PWC. Except to "re -seed" for upset conditions and to sometimes add
supplemental food.
18

PART II. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
DD. Hazardous Waste Discharge
The Public Works Commission prohibits the discharge of .hazardous substances
(according to 40 CFR 261) or any hazardous wastes as determined by PWC, to the
sanitary sewer system. All hazardous wastes should be disposed of in, accordance
with North Carolina Hazardous Waste Management rules and Solid Waste
Management Law (15A NCAC 13A).
19

PART III. IU Name: DAK Americas, LLC
SPECIAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
PART III. SPECIAL PERMIT CONDITIONS
A. Biotoxicity Monitoring
If it is found that the permittee's effluent has a significant toxic impact upon the
municipal wastewater treatment system and/or its receiving stream, the permittee ,
shall be required, upon written notification from the PWC, to conduct Biotoxicity
monitoring on the effluent being discharged. The severity of the permittee's effluent
toxicity shall determine the frequency of the Biotoxicity monitoring.
B. Toxicity Control
Upon determination of toxicity in the permittee's effluent, the permittee shall be
required to identify and eliminate the source(s) of the toxicity from the final
discharge.
C. Flow Monitoring
The permittee shall record and report (to PWC) daily wastewater discharge flows
from this facility. Flow data shall be recorded from the first of the month to the last
day of the month and submitted to PWC by the tenth of the following month.
Where flow monitoring is required by PWC the equipment must meet current PWC
flow meter specifications. The installed flow meter shall be calibrated once January -
June and once July -December and documentation of the calibration event shall be
submitted to PWC. Additional calibrations shall be performed by the Permittee, at
the request of PWC, in the event of significant questions concerning the accuracy of
the meter, including but not limited to:
1. Increase or decrease in sewer flow greater than twenty-five percent (25%) in
two consecutive months.
2. Increase or decrease in "sewer flow to water consumption" ration above ten
percent (10%) in two consecutive months.
PWC shall be notified within twenty-four (24) hours of any malfunction, damage, or
repairs to the flow meter. PWC reserves the right to revert to billing for sewer based
on water consumption in the event of the failure of the permittee's flow meter to
perform properly; or the failure of the permittee to submit the required data and
documentation to PWC in a timely fashion.'The permittee must contact PWC for
current flow meter specifications prior replacing a flow meter for any reason.
20

PART III. IU Name: DAK Americas, LLC
SPECIAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
D. Relationship Between DAK Americas and Dupont Tejin Films
It is recognized that DAK Americas and Dupont Tejin Films have gone to
considerable and commendable efforts to foster a good working relationship with
each other in light of a potentially precarious situation. It should be noted that DAK
Americas being the permit holder is responsible for the quality of effluent from their
wastewater treatment facility. DAK Americas and Dupont Tej in Films must continue
to work together to ensure that the conditions of this permit are met.
To satisfy regulatory conditions, the following conditions must be met: Dupont Tejin
Films, as a "user" of the City's sewer system, must be bound by the conditions of this
permit including but not limited to Right of Entry, Availability of Records and
Reports, Duty to Provide Information, and Re -Application for Permit Renewal.
Upon fmalization of agreement between DAK Americas and Dupont Tejin Films for
use of DAK Americas treatment facility, the Public Works Commission will be
provided a copy for review and approval.
E. Slug/Spill Control Plan
The permittee shall provide protection from accidental discharges of prohibited
materials or other substances regulated by this permit. At the request of the
permitting authority the permittee shall develop, obtain PWC approval, and
implement a written Slug/Spill Control Plan within 120 days of the effective date of
this permit. This plan shall include, but is not limited to:
• Methods to prevent the discharge of incompatible or. prohibited pollutants to the
sanitary sewer system.
• Description of discharge practices, including non -routine batch discharges.
• Description of stored chemicals.
• Procedures for immediately notifying the POTW of slug discharges that would cause
a violation of40 CFR 403.5(b) (see General Condition AA, Page 17), with
procedures for follow-up notification within 5 days.
• If necessary, procedures to prevent adverse impact from accidental spills, including
inspection and maintenance of storage areas, handling and transfer of materials,
loading and unloading operations, control of plant site run-off, worker training,
building of containment structures or equipment, measures for containing toxic
organic pollutants (including solvents), . and/or measures and equipment for
emergency response.
21

PART IV.
PERMIT SYNOPSIS
City of Fayetteville, North Carolina
Public Works Commission
Industrial Pretreatment Program Permit
PART IV. IUP Synopsis
A. IUP Basic Information
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
Receiving POTW name:
Rockfish Creek Water Reclamation Facility
POTW NPDES#:
NC0050105
IUP Name:
DAK Americas LLC
IUP Effective Date:
Effective Date of this Permit
IUP Expiration Date:
Expiration Date of this Permit
B. IU Survey & Application form
Attached is a completed copy of the Industrial User Wastewater Survey •&
Application Form.
C. IU Inspection form
Attached is a copy of the most recent Industrial User Inspection.D. RATIONALE
FOR LIMITATIONS:
as listed on the IUP Limits Page(s), PART I, Section B of the IUP.
PIPE O1
RATIONALE # 1:
Categorical Pollutant_ Limits and Conventional Pollutant Limits, with no Over Allocation
situation
As listed in 40 CFR 414, Flow, BOD, and pH.
22

Appendix B
Reactor MLVSS vs. Time

2400
2200
2000
• 1800
N
> 1600
L
1400
1200
1000
Control Reactor: Existing Facility Wastewater
Sludge Age#3
LID CO al
N N N N N N OM
LD lD LD ▪ • lD lD lD LD
�-I N M 00 el O % -I N M fit' Lfl lD N 00 m O r I N
\ \ \ \ \ \ \ \ \ rl % -1 rl e-1 N N N
n N N N- N N r n r- N N N N
Date

2000
1800
1600
1400
• 1200
E
N 1000
▪ 800
2
600
400
200
0
Fully Pretreated PET/Existing Facility Wastewater
Sludge Age #1
I I I I I I 1 I 1 1 I I 1 II f I 1 I 1 1 1 1 1 1
d In lD I- 00 Ql O x -I N M Cr 111 ID N 00 al O c-I N M Cr L l l0 b 00 Ql O r-I N
lD l0 LC) LO LID l0 lD I� I. I� I� N. I- I� N N N N N I-
Date

ale
V V V V V V-J V V V V V V Ol 01 Ol 01 01 rn rn
\ \ \ \ \ \ \ \ \ \ \ \ \ V V V V V V V V
N N I_4 F-' F-a \ \ \ \ \ \ \ \ \ W Ni Ni NJ Ni N N
Ni I- 0 l0 00 V Ol Ul 4 W N I- 0 l0 00 V 01 U1 A UJ N I-1 0 l0 00 V 01 (J1 -A
I 1 1 I I I 1 1 1 1 1 1 L 1 1 1 L I 1 I 1 1 1 I 1 1 1 I 1
•
Z #any agpnIS
as}ennaiseM 2uRsix3/13d paleanaad Mind
0 7
00Z
0017
009
008
0001
00ZZ
00171
009i
0081
000z

3400
3200
3000
2800
2600
bn 2400
2200
2000
1800
1600
1400
1200
1000
Fully Pretreated PET/Existing Facility Wastewater
Sludge Age #3
Cf L11 l0 N 00 01 O i- I N M Ct lD N 00 01 O N m L11 00 Ol O a I N
N N N N N N M \ \ \ \ \ \ \ \ \ e-I ri �-� -I e r 1 i"i r-I ‘-1 .—i N N N
\ \ \ \ \ \ \ N N - N- n N n N- N. N \ \ \ \ \ \ \ \ \ \ \ \ \
l0 lD l0 l0 l0 lD lD N
Date

E
2
5000
4800
4600
4400
4200
4000
3800
3600
3400
3200
3000
2800
2600
2400
2200
2000
Fully Pretreated PET/Existing Facility Wastewater
Sludge Age #4
t.
6/24 6/26 6/28 6/30 7/2 7/4 7/6 7/8 7/10 7/12 7/14 7/16 7/18 7/20 7/22 7/24 7/26
Date

3200
3000
2800
2600
2400
▪ oa
E 2200
• 2000
2 - ▪ 1800
1600
1400
1200
1000
Partially Pretreated/Existing Facility Wastewater
Sludge Age # 3
d- Irj l0 00 al O c--1 N M d' 111 l0 I-, 00 Ol O % -1 N M d' N- 00 CI O r1
N N Ni Ni N N M \ \ \ \ \ \ \ \ \ c-I % 1 c-I %-1 rl c-I ci r1 ri a -I N N
Date

Appendix C
Reactor Operational Data
1

Reactor Data Used for Biological System Evalua Ion (July 20 through July 27, 2009)
Reactor .
Operational
Sludge Age
(days)
pH
Mixed Uquor Average VSS
• Concentration (mg/L)
Influent Average
Total COD (mg/L)
Influent Average
Soluble COD (mg/L)
Influent Average
Particulate COD
(mg/L)
Influent Average
CBOD (mg/L)
Effluent Average
Soluble COD (mg/L)
Effluent
Average VSS
(mg/L)
Effluent Average
CBOD (mg/L)
Average SOUR (mg
02/ mg VSS hr)
Average SVI
(ml/g)
DAK Only
65 :
6.62
1473
5800
5547
253
3180
256
51.5
5.0
0.0065
177
DAK/PET Coagulated Blend
4.4 •
8.13
515
4550
3543
1007
2197
304.0
183.0
119.3
0.0185
46
DAK/PET Coagulated Blend
30.2
8.05
1085
4550
3543
1007
2197
268.8
44.8
70.8
0.0098
102.2
DAK/PET Coagulated Blend
71.0
7.90
1950
4550
3543
1007
2197
153.3
23.5
5.0
0.0035
231.5
DAK/PET Coagulated Blend
89.1
8.21
2842
4550
_ 3543
1007
2197
167.8
41.1
36.8
0.0028
318.4
DAK/PET Non -Coagulated Blend
67.7
8.22
2073
7235
3820
3415
186.5
30
0.0046
. 147
Notes:
1) DAK/PET Coagulated Blend at89 days, 214 mg/LCBOD assumed as outlier and not Included In average calculation
2) For CBOD values less than the detection limit, 25% of the detection limit assumed or 5 mg/L
3) Average SOUR data and SVI data calculated from July 15 through July 27 •
4) PET non -coagulated wastewater assumed to have a TSS concentration of 902 mg/L

Appendix D
Biokinetic Constant Calculations

Determination of Klnetceoelndentl •
1) Estimation of the Speclflc Substrate Umlration Rate Constant
Reactor Valuate 19 L
Conversion factor
1.01 lmit CO Dim VSS
First Order
Substrate UII
proximation
nation Rate
Reactor
Operational
Sludge Age (B)
(days)
1/0(days)
1/0(hours) _
Mixed liquor Average VS5
Concentration (mg VSS/L)
Flow Rate
(L/hour)
Mixed Liquor Average Biomass COD
Concentration (mg biomass CODA)
Influent Average Total
COD(teg/L)
Influent Average
Soluble C00 (mg/Li
Effluent Avera5e3oluble COD
(mg/LI
Influent Average
Biodegradable Soluble COO
(m3/11
Effluent Average
Biodegradable Soluble COD
(ma/L) - .
yaxis
q• 0(So.S)/AV
Wad,
(Se)
OAK/PET Coagulated Blend
aA
0117
0.00946
5145
0074
731
4550
3543
304.0
3390
1507
0.0146
150.7
OAISPET Coagulated Blend
' 30.1
0.033
0.00138
1065
0.073
1541
4550
3543
168A
3390
115.5
0.0116
1155
0AK/PET Coagulated Blond
71.0
0014
000059
1950
0075
1769
4550
3543
153.3
3390
5.0
'0.0069
5.0
? Om60 -
a 0.0150
a
E nolm
O0150
0.0100
0.0050
a0030
aq
First Order Appraalm t10n: q vv.5e
it' •0.711476
coo 60.0 80.0 100.0 110.0 140.0 160.0
gmnentebde(ndable 6oluble COD (ms/L)
1) Estimation of the Veld Coefficient and Aembla Decay Coefficient
Ungar Form of Blomau Material Balance: Plot of Specific Substrate UUIhaBan Rate es.1/B
00300
2
nmm
aD150
m1 0
I
'--_'-'
1A3176L+Oo07331
__ •
_
-
Rs•0.964723
I0.00000 000100
0.0010a
600300
0.00100
0.00300
1/0 (M)
0.00600
0.00100
0.00100
0.00300 0.01000
UUmate oxygen Use Coel0dents
Reactor
Operational
Sludgehge (0)
(days)
1/0(days)
Average SOUR
(mg 01/tog vss
hr)
5pedlk Substrate U111UatIan Rate
- )q)(houn)
OAK/PET Coagulated Blend
4A
0.127
0.0165
0.0146
DAY/PET Coagulated Blend
50.1
0.033
0.0098
0.0116
0AK/PET Coagulated 0lend
71.0
0.014
0.0035
O0069
2
Plot a/ pacific Oxygen
Uptake Rate V3 Specific Substrate Utilization Rate
game0
0.0160
09
('
St
a 0At00
a
_5.0. Fd• 0.91211
R'•0.911111
---
e.
i0.0010
00000 60350
0.0100 0.0130 °moo
SpedlicSubstrate 001lratian9ate (gl(hn)
00130
Om00
AR Three Reactor Data Points Used
R(specific substrate utilization rate constant)
Slope •
0.000110 I/mg V55 biomass ht.
0.001880 Lima VS5 biomes, day
MI Three Ruder Data Points Used
Slope • 5/7 Tag
Intercept • Kd/y 0.007
Veld Coef0cient 0.46 mg V3S/mg VS5
Decay COeflident 0.0031 1/hr
0.077 1/day
Oxygen Use coefficients
Slope..
Intercept • Is
0.66 mg Ol/mg COD
h • 0.0003 mg 01/mg VSS hr
00071 mg 0l/mg VSS day

Appendix E
Aeration Calculations

Evaluation of Operational Data to Determine Aeration Capacity
DAK Americas Cedar Creek WWTP
Month Avg DO Avg Temp. OUR Aeration Avg Infl Mass of VSS Csw, saturated DO Csw-DO .OUR AAOR O^(T-20) Cs20-DO AAOR AAOR
in AB Power COD in System in wastewater at T in Basin (9.07-DO) at 20 C at 35 C and Cs = 2 mg/L
(mg/L) (Degree C) (mg/L/hr) HP Lb/day Lb (mg/L) (mg/L) Lb/day Lb 02/hp-hr (mg/L) Lb 02/hp-hr - Lb 02/hp-hr
2007
1 4.2 23.0 4.4 175 3375 52250 8.56 4.4 1057 0.25 1.074 4.92 0.26 0.37
F 3.5 20.0 6.3 149 4210 60563 9.07 5.57 1513 0.42 1.000 5.57 0.42 0.53
M 3.7 20.8 6.0 140 3675 57475 8.93 5.23 1441 0.43 1.019 5.37 0.43 0.57
A 4.5 19.7 5.9 140 3300 45600 9.13 4.63 1417 0.42 0.993 4.57 0.42 0.65
M 4.1 21.8 7.1 140 3700 49700 8.76 4.71 1705 _ 0.51 1.044 5.02 0.52 0.73
1 3.2 26.8 6.3 143 '3550 50900 7.98 4.78 1513 0.44 1.175 5.87 0.46 0.55
1 2.7 27.4 7.7 209 3840 54600 7.89 5.19 1849 0.37 1.192 6.37 0.38 0.42
A 2.4 25.6 7.2 300 5000 47800 8.15 5.75 1729 0.24 1.142 6.67 0.24 0.26
S 4.2 24.8 7.3 140 3500 65500 8.27 4.07 1753 0.52 1.121 4.87 0.56 0.81
0 5.1 21.6 5.4 140 2840 45283 8.79 3.69 -1297 0.39 1.039 3.97 0.40 0.71
N 4.7 14.1 6.3 140 3170 55575 10.27 5.57 1513 0.45 0.869 4.37 0.41 0.65
D 4.2 18.1 6.6 200 4380 65708 9.43 5.23 1585 0.33 0.956 4.87 0.32 0.46
2008
J 5.1 17.6 5.5 200 3640 59217 9.53 4.43 1321 0.28 0.945 .3.97 0.26 0.46
F 4.4 18.7 5.7 200 3390.. 52092 9.32 4.92 1369 0.29 0.970 4.67 0.28 0.42
M 5.1 18.0 5.6 173 3160 52567 9.45 4.35 1345 0.32 0.954 3.97 0.31 0.55
A 4.6 19.2 6.0 127 2840 46233 9.22 4.62 1441 0.47 0.981 4.47 0.47 0.73
M 4.2 21.1 6.7 140 2580 52408 8.88 4.68 1609 0.48 1.026 4.87 0.49 0.70
Average 3538 1498 0.39 0.39 0.56

Projected Aeration Requirements
1.2 MG Aeration Basin 4.4 MG Aeration Basin
COD MLVSS 02 Reqd AAOR - HP reqd HP MLVSS 02 Reqd AAOR HP reqd HP,
Available Available
(Ib 02/hp- - (Ib 02/hp-
(Ib/day) (Ib) (lb/day) day) (Ib) (Ib/day) day)
Startup 4430 35200 3177 12 265 405 25800 3110 12 259 900
CPR Best Case, Phasel 6430 51000 4611 12 384 405 37300 4512 12 376 900
DAK Normal Phase II 8420 66900 6039 12 503 405 49000 5910 12 493 900
Startup 5740 45700 4117 12 343 405 .33400 4029 12 336 900
CPR Worst Case, Phasel 11030 87800 7912 12 659 405 64300 7743 12 645 900
DAK Normal Phase II 16040 130000 11522 12 960 405 95000 11270 12 939 900
Startup 9020 71800 6470 12 539 405 52600 6332 12 528 900
CPR Best Case, Phasel 11020 87700- 7905 12 659 405 64200 7735 12 645 900
DAK Abnormal Phase II 13020 103000 9335 12 778 405 75800 9139 12 762 900
Startup 10340 82300 -7417 12 618 - 405 60300 7259 12 605 900
CPR Worst Case, Phasel 15625 124000 11205 12 934 405 91000 10968 12 914 900
DAK Abnormal Phase II 20900 166000 14989 12 . • 1249 405 122000 14672 12 1223 900
02 Reqd estimated from Pilot Study data as 0.66 x COD + 0.0072 x MLVSS.
AAOR (Apparent Actual Oxygen Transfer Efficiency) determined from evaluation of existing DAK operational data with adjustments
for anticpated higher temperature and surfactant concentration.