NC0003719_Engineering Analysis_20041021

To: Susan Wilson
From : Paul Rawls
Date: 8/30/2004
Subject : Regional Comments: EAA DAK Americas, Cedar Creek Site, NPDES PermitNumber
NC0003719. Cumberland County
I offer the following comments as regional response for the EAA by John Eick of Stearns & Wheler
dated 8/26/2004
The report does not address, in detail, the associated cost of sending untreated wastewater to the
Fayetteville WRF.
The report should, in my opinion, have a breakdown of what the actual costs would be to send the
untreated wastewater to the City based on influent data.
If that data is not available then at least three months of data should be collected to determine what
base rates and surcharge costs would be as compared to "current cost" to defend the selected option
The report indicates that going to the City would somehow make the site less attractive to recruiting
potential industries.
There is no explanation of why this comment is made. This should be explained,
The Industrial User permit applic4tion contained in the EAA indicates that the company(s). discharge
50,000 to 60,000 gallons per day of NON -Contact Cooling Water. The Company should indicate if
this water could be reijsed in the process.
If you have questions or comments regarding these comments please call me at [phone].
1 of 1 .8/30/2004 1'.54 PM

DENR R
AUG 2 7 2004
Mrs, Susan Wilson.
North Carolina -Division of _Water Quality:
1617 Mail Service Center
Raleigh; NC.27699-1617.
Dear Mrs. Wilson,
0
Cape Fear. Site:.. ,
3500- Daniels Road; .NE
Leland, NC 28451.
-August 26, 2004
Subject;. Engineering Alternative Analysis Submittal
Permit NC00037.1.9
DAK Americas Cedar Creek Site
As indicated in our letter=dated July 15; 2004 DAK Americas is submitting an Engineering:
Alternative Analysis: (EAA) for` the Cedar'CreekSite as requested by the Division: Please. find
enclosed:three copies: of the EAA for your review: -An additional copy will be sent .to.Mr. Paul.
Rawls in .your Fayetteville. Regional office.
Once the Division .has reviewed the.EAA; we will anticipate anothermeeting to: be:scheduled to discuss the next step.
If youhave any question_ or. concerns=please contact me at:910-371-5082 or 9 10-262-2288 or
Penny Mahoney at-910-371=5232.
Sincerely,
Jeffrey.C.:Richardson
c: -. File,Rooin .
Paul Rawls,:NCDWQ Fayetteville Regional Office
Ms. Penny Mahoney',:DAK Americas

ternatives Analysis
To
isposal Alternatives
CAK Resins, LLC
•: 3468 Cedar Creek Road
Fayetteville,North Carolina 28312
Cumberland County = -
NPDES Permit. No. — NC0003719
Stearns:& Wheler,.PLLC. .
3 128 Highwoods Boulevard,. Suite.140
Raleigh,: North. Carolina 27604
•Phone..[phone] Fax: [phone]
Stearns,:& Wheler; PLLC
Environmental Engineers and Scientists

Table of Contents
Section 1 Introduction 1-1
1.1 Purpose 1-1
1.2 Report Outline 1-1
Section 2 General Information 2-2
2.1 Plant Description 2-2
2.2 Current Wastewater Flows and Loading 2-5
2.3 NPDES Permit 2-6
2.4 Industrial Pretreatment Permit 2-6
Section 3 Wastewater Disposal Alternatives Analysis 3-1
3.1 Alternative No. 1— No Capital Improvements to Cedar Creek WWTP and
Maintain NPDES Permit 3-1
3.2 Alternative No. 2 — Upgrade Cedar Creek WWTP and Maintain NPDES Permit
3-2
3.3 Alternative No. 3 — Discharge Untreated Wastewater to Fayetteville PWC's
Rockfish Water Reclamation Facility 3-3
3.4 Alternative No. 4 — Upgrade Cedar Creek WWTP and Discharge to Fayetteville
PWC's Rockfish Reclamation Facility 3-4
3.5 Alternative No. 5 — Land -based Disposal Systems 3-6
3.6 Alternative No. 6 — Wastewater Reuse 3-8
Section 4 Opinion of Costs 4-1
4.1 Capital Costs 4-1
4.2 Operations and Maintenance Costs 4-1
4.3 Present Worth Analysis 4-2
Section 5 Recommendation 5-1
6
Stearns & Wheler, PLLC
LEnvironmental Engineers and Scientists
DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

List of Tables
Table
2-1 Wastewater Treatment Facility Identification Summary
2-2 Summary Of Wastewater Treatment Facility Components
2-3 Average Operational Parameters (January — June 2004)
2-4 Wastewater Characteristics (January — June 2004)
4-1 Opinion Of Probable Capital Cost
4-2 Opinion Of Probable O&M Cost
4-3 Opinion Of Probable Present Worth Cost
List of Figures
Figure
1 Wastewater Treatment Facility Aerial Photo
2 Existing Wastewater Process Flow Diagram
3 Alternative A — Wastewater Treatment Facility Upgrade
4 Alternative B — Wastewater Treatment Facility Upgrade
Appendix
Appendices
A NPDES Permit Modification
B Fayetteville PWC — Industrial User Wastewater Survey and Permit Application
C Vendor Literature
D Cumberland County Soils Information
E Opinion of Probable Capital Costs
F Opinion of Probable Operations and Maintenance Cost
Stearns & Wheler, PLLC
Environmental Engineers and Scientists
ii
DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Section 1 Introduction
1.1 Purpose
This Engineering Alternatives Analysis (EAA) is being prepared as part of the National
Pollutant Discharge Elimination System (NPDES) permit modification required by the
North Carolina Division of Water Quality (NC DWQ) for the sale of Monsanto
Agricultural Company's Wastewater Treatment Facility located on Cedar Creek Road in
Fayetteville, North Carolina to DAK Resins, LLC. The EAA's objective is to evaluate
wastewater disposal alternatives to determine the most cost-effective and
environmentally sound disposal solution.
1.2 Report Outline
This evaluation follows the outline described in the guidance document for evaluating
wastewater disposal alternatives prepared by the NC DWQ as follows:
• Location and description of the existing wastewater treatment facility
• Current wastewater flows and loadings generated at the facility
• NPDES permit requirements for discharging treated wastewater to the Cape Fear
River
• Industrial Pretreatment permit requirements issued by the Fayetteville Public Works
Commission (PWC)
• Evaluation of disposal alternatives, as outlined in the EAA guidance document
• Present worth analysis of potential disposal alternatives
• Recommendations for wastewater disposal
Stearns & Wheler, PLLC
Environmental Engineers and Scientists
1-1
DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Section 2 General
Information
2.1 Plant Description
The former Monsanto Wastewater Treatment Facility owned by the Monsanto
Agricultural Company, presently operated by DAK Resins is located on Highway 53
(Cedar Creek Road), south of Fayetteville in Cumberland County. The DAK Services
Complex provides utilities and treats wastewater for the DAK Resins facility, the DuPont
Teijin Films facility and internal use. Treated wastewater is discharged into the Cape Fear
River, which is classified as Class C water, as shown on Figure 1. Table 2-1 provides a
summary of the identification information for the wastewater treatment facility.
TABLE 2-1
WASTEWATER TREATMENT FACILITY IDENTIFICATION SUMMARY
Facility Name
DAK Resins, LLC
Facility Address
3468 Cedar Creek Road
County
Cumberland
Facility Phone/Fax
[phone]/[phone]
NPDES Permit No.
NC0003719
Discharge Receiving Stream
Cape Fear River
Stream Class
C
River Basin
Cape Fear
Outfall Location (Latitude/Longitude)
34°58'08"/ 78°46'58"
Permitted Flow (mgd)
0.5
The wastewater treatment facility consists of the following components listed in Table 2-
2.
Stearns & Wheler, PLLC
Environmental Engineers and Scientists
2-2
DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

TABLE -2-2 .
SUMMARY .OF.WASTEWATER TREATMENT FACILITY: COMPONENTS
-Facility Component
Description :
Spill Basin-
_"
One 1.:0 MG in -ground' concrete. PVC: lined basin.
used as a temporary holding basin.:
Equalization Tanks .:. ..
Two 660,500-gallon: aboveground, fiberglass :tanks.
Each 55 feet in diameter with. a 37 foot side .water
depth:. .:... .:. " ...:: .
PH Pit • :
An in=ground : concrete.. pit: with _ - three. 'chambers.
providing . a total capacity of: 140,060 i gallons:
. Location where nutrients (urea .and phosphoric acid)
are: added; pH .adjustment with sodium : hydroxide;
and addition of steam during winter operations
Aeration Basin No': l
Aeration Basin No. 1; currently not in service, is a
4.4 MG" concrete basin .. used as - an
emergency/temporary-holding .basin: The basin is:
equipped with two .75 horsepower (Hp).aerators and
six =1.50 (Hp) aerators.::.
Extended Aeration
Activated. Sludge Process.
Aeration Basin No: 2
Aeration basin:No:2 is a: 1.2MG. concrete basin :with
a 65-foot:side.water depth and equipped with seven
aerators and two: 75 .hp mixers:: Five aerators are:
fixed (two 40 hp, two 50 hp, arid one 75 hp) and two
floating aerators, each:40 hp.
.
Chemical: Lift Statiori .
Two pumps; one -duty: pump with a capacity of 160
gpm and a second stand-by unit with:. a capacity of
300.OM. :. - ..
Secondary. Clarifier'
One secondary .clarifier: 90 = feet.. in . diameter with : a
14-foot side water depth:. ...
' RAS/WAS Pump Station'
Three pumps each 25. horsepower witha capacityof
900.gpm.: Commondischarge manifold;.
Parshall Flume
One -Parshall :flume. is. used for measuring : flow
discharged from the facility:
Aerobic Digester
One : in -ground concrete:: basins " equipped -• _with
surface :aerators. . Digester:. has. a "capacity of:.0:55.0
MG and is equipped with . two 25horsepower
aerators:
Sludge Storage:Basitl . "
One _.:1.:0 MG in -ground :concrete basin with,two 25
horsepower mixers
Sludge Drying Beds : .
Threesludge drying. beds,: each 240 feet by 30:feet:.
A.process flow diagram of the existing treatment facility is provided in Figure 2." A brief
description of the process flow follows.
OrStearns. & Wheler, PLLC
e` Environmental Engineers and Scientists
2-3 DAK-Resina
Cedar Creek Plant, North, Carolina
Engineering Alternatives Analysis

Wastewater generated from resin manufacturing at the DAK Resins facility and the
DuPont Teijin Films facility is currently conveyed to the two equalization basins. The
equalization basins dampen variations in flow and organic concentrations before
discharging the wastewater to the biological treatment process.
Flow from the equalization basins is routed to the pH pit. Urea and phosphoric acid are
added to supplement the nutrient deficient wastewater and sodium hydroxide is added for
pH adjustment. During winter operations, steam is added to increase the wastewater
temperature to improve the biological degradation rates.
The activated sludge process is a 1.2 MG in -ground concrete basin with a 6.5-foot side
water depth, which receives flow from the pH pit. Seven surface aerators provide oxygen
to the process biology. Two 75 horsepower mixers supplement the mixing achieved by
the seven aerators to maintain the biological solids in suspension.
Aeration basin effluent flows to a 90-foot diameter secondary clarifier with a 14-foot side
water depth. Discharge from the secondary clarifier flows through an effluent Parshall
flume followed by the existing chlorine contact basin, no longer used, and directed to the
plant outfall. A portion of the settled solids from the secondary clarifier is returned to the
aeration basin and the remaining solids wasted to the aerobic digester.
The aerobic digester is a 0.550 MG in -ground concrete basin equipped with two 25
horsepower surface aerators. Digested solids are conveyed to a 1.0 MG sludge -settling
basin to allow thickening of the stabilized solids before applying the solids to the sludge
drying beds. The facility recently utilized a contractor, who used a belt filter press to
dewater the stabilized solids during wet periods of the year. Dewatered solids are
disposed of at the nearby landfill. Decant from the 1.0 MG sludge settling basin is
returned to the aeration basin.
Stearns & wheler, PLLC
Lel Environmental Engineers and Scientists
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DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Table 2-3 summarizes the average operational parameters for the activated sludge process
from January. through June of 2004.
TABLE 2-3
AVERAGE OPERATIONAL PARAMETERS (JANUARY — JUNE 2004)
_-
r.?. f..° '-"'.:."*'pr:��.1s..Y`— -:, '�.'"!r'ire;.�.}:td}`S ' 'j,;:,:�-,&++.:' .�-.... .;-
v.,x wK„ y•...�`_Vi...`_i..,ies• .^A+r.4...i ,' '''''
Mixed Liquor Suspended Solids (MLSS)
4,644 mg/L
Mixed Liquor Volatile Suspended Solids (MLVSS)
3,917 mg/L
MLVSS/MLSS Ratio
0.84
Food to Microorganism ratio (F/M)
0.18
Solids Retention Time (SRT)
26 days
Secondary Clarifier Underflow Concentration
5,531 mg/L
pH
7.6
2.2 Current Wastewater Flows and Loading
The flows and wastewater constituents are representative of the blended wastewater from
the DAK Resins and DuPont Teijin Films facilities. Section 15A NCAC 2H .0219
provides minimum design flows from typical residential and commercial sources, which
are not applicable to this treatment facility because the wastewater flow is industry
specific. Flow projections are therefore based on available operational data. Both
facilities already implement reuse of plant process water and employ low -flow devices
} where applicable to reduce wastewater generation.
Table 2-4 summarizes the current minimum, average, and maximum flows and loadings
to the treatment facility for the period of January through June 2004.
Stearns & Wheler, PLLC
Environmental Engineers and Scientists
2-5
DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

TABLE 2-4
WASTEWATER CHARACTERISTICS (JANUARY — JUNE 2004)
.F_ i;l£` e�`:-zc�cy',9y.3.Tf,.. _:P .;+.;t'.; :4;F'. r�._. �:.':.L`RiC_.�n?.'"_ .F
- ki ii'�:ia:.,Ce.._ '.{,rvj.23�� :.�'. Z': '"iS':ti�A{.ii
,4`4=:s>�;:.:t., -Parameter : ;-' ,,h .; .�,.;.;
u�z�, ,h;:��;::��... - ...:�
._l'i`. 'c-i':iti�:{2:�`��'„ivt.:
,. �.:kr
��YI:inmum>�
s ..`
��A�exagc;�
'' _ _µw4f£'4:��ii4
:"Y...'Yh���{.^•,^S:"y:_;��ct`�'
;a:
r:.la�umum�,��
Effluent Flow (gpd)*
0**
231,000
416,000 e
Chemical Oxygen Demand, COD (mg/L)
2,240
4,746
12,740
Chemical Oxygen Demand, COD (lb/day)
1,848
6,615
18,919
Total Suspended Solids, TSS (mg/L)
5
183
1,170
pH
5.20
7.61
8.40
Temperature (°C)
13
20.6
29.1
**Clarifier shut down **561,000 gallons were treated off -site during upset conditions in March
2004
2.3 NPDES Permit
On June 7, 2004, the NC DWQ NPDES Permitting Unit issued an NPDES permit
modification to DAK Resins for the operation of the former Monsanto Wastewater
Treatment Facility for a permitted discharge of 0.50 mgd. The NPDES permit was
contingent upon DAK Resins submitting an EAA demonstrating the need to discharge
treated process water to the Cape Fear River. A,copy of the NPDES permit modification
is provided in Appendix A.
2.4 Industrial Pretreatment Permit
As part of the EAA, an evaluation of discharge to a publicly owned treatment works
(POTW) must be performed. A copy of the industrial wastewater survey and permit
application provided by the Fayetteville PWC is provided in Appendix B.
Stearns & Wheler, PLLC
4..1 Environmental Engineers and Scientists
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DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Section 3 Wastewater
Disposal Alternatives
Analysis
In order to provide cost-effective, environmentally sound wastewater disposal, several
wastewater treatment alternatives were considered. They are as follows:
3.1 Alternative No. 1— No Capital- Improvements
to Cedar Creek WWTP and Maintain NPDES
Permit
Alternative No. 1 involves operating the existing wastewater treatment plant without any
modifications because it currently provides secondary treatment within the NPDES
permit limits established when Monsanto Agriculture Company owned the facility. No
major capital improvements appear necessary at this time in order to meet the currently
proposed NPDES permit limits. This alternative does not, however, account for
improvements that would allow the existing WWTP to operate more cost effectively.
The advantages of this alternative include:
1. No capital investment at this time to meet the current NPDES requirements.
2. Site is attractive for recruiting other industries.
A few disadvantages are, however:
1. Does not optimize process to reduce power consumption
2. Does not optimize process to reduce chemical feed requirements
3. Continued operation of the WWTP to meet NPDES requirements.
4. Continued solids disposal
Stearns & Wheler, PLLC
Environmental Engineers and Scientists
3-1 DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

3.2 Alternative No. 2 — Upgrade Cedar Creek
WWTP and Maintain NPDES Permit
Alternative No. 2 involves providing new process equipment that would allow the
existing facility to operate more cost effectively (i.e. reduced operations and maintenance
cost), although these improvements are not necessary to meet the currently proposed
NPDES limits. The proposed improvements would include a new aeration system and
final clarification system to reduce power consumption and enhance solids removal.
Because previous WWTP upgrades provided treatment capacity for larger organic
loadings and higher process flows, the WWTP is oversized for the current hydraulic and
organic loadings. The existing aeration basin has a capacity of 1.2 million gallons with a
6.5-foot side water depth. The basin's large footprint requires significant mixing energy,
which is accomplished with seven surface aerators and two mixers. In addition, the
shallow tank depth results in poor oxygen transfer. Unfortunately, these factors result in
significant power consumption.
To reduce operations and maintenance costs, several options appear feasible. As shown
on Figure 3, one possible alternative would be to convert the existing equalization tanks,
which are much smaller than the existing aeration tanks, into two sequencing batch
reactors (SBRs). The current aeration tanks and clarifier would be abandoned.
As shown on Figure 4, a second alternative would be to convert the existing secondary
clarifier into an aeration basin and construct a dissolved air flotation (DAF) system for
final clarification. A DAF system would be constructed above ground to avoid the
excavation cost associated with a new below ground clarifier.
4Stearns & Wheler, PLLC
.1 Environmental Engineers and Scientists
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DAK Resins
Cedar Creek Plant, North Carolina
Engineering Altematives Analysis

Regardless, both alternatives appear similar in cost, but further evaluation will be
performed as part of a preliminary engineering analysis. Catalog information for both
possible treatment options is included in Appendix C.
Some advantages of an upgraded WWTP are:
1. Significantly reduces power consumption
2. Reduces chemical feed requirements
3. Reduces sludge production
4. May reduce the need for steam addition to heat the wastewater during the winter
months
5. Site is attractive for recruiting other industries.
Some disadvantages are:
1. Construction sequencing would be critical to maintain production and ensure
compliance with the NPDES permit.
2. Continued solids disposal
3.3 Alternative No. 3 — Discharge Untreated
Wastewater to Fayetteville PWC's Rockfish
Water Reclamation Facility
Alternative No. 3 would allow DAK Resins to abandon the existing Cedar Creek WWTP
and discharge untreated process water into Fayetteville PWC's wastewater collection
system via a new pumping station located west of the manufacturing facility. While this
alternative would allow DAK Resins to abandon its wastewater treatment facility
Stearns & Wheler, PLLC
Environmental Engineers and Scientists
3-3 DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

eliminating the need for further capital investment and eliminating significant power
consumption costs, it would result in DAK Resins being subject to discharge user fees for 1111111.11111
flow and possible surcharges for high organic loadings. Therefore, the cost savings
associated with abandoning the Cedar Creek WWTP must be -oin aced o the costs of
increased wastewater fees from Fayetteville PWC.
Some advantages of this alternative are:
1. Allows DAK Resins to discontinue its NPDES permit
2. Allows DAK Resins to abandon its wastewater treatment plant and associated
liabilities
3. DAK Resins would abandon its solids handling facilities
4. Significantly reduces power consumption
A few disadvantages of this alternative are:
1. DAK Resins would be subject to fees for wastewater treatment
2. DAK Resins would be subject to financial surcharges when organic loadings are
higher than allowed in Fayetteville PWC's pretreatment ordinance.
3. Site becomes less attractive for recruiting potential industries.
3.4 Alternative No. 4 — Upgrade Cedar Creek
WWTP and Discharge to Fayetteville PWC's
Rockfish Reclamation Facility
Alternative No. 4 involves construction of additional treatment processes to reduce power
consumption and reduce organic concentrations in the wastewater to avoid financial
surcharges from Fayetteville PWC. As with Alternative No. 3, a modified biological
/4Stearns & Wheler, PLLC
.1 Environmental Engineers and Scientists
3-4
DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

treatment process would still be necessary to optimize operations and maintenance costs,
but not to meet the current NPDES permit requirements.
Some advantages of this alternative are:
1. Allows DAK Resins to discontinue its NPDES permit
2. Significantly reduces power consumption
3. Process upsets would result in violations of the pretreatment ordinance and not an
NPDES permit
A few disadvantages of this alternative are:
1. DAK Resins would be subject to fees for wastewater treatment
2. Management of a pretreatment program becomes necessary
3. The solids handling process would still need to be managed
4. Process upsets could result in additional financial surcharges from Fayetteville
PWC
5. Site becomes less attractive for recruiting potential industries.
3.5 Alternative No. 5 — No Upgrades to the Cedar
Creek WWTP and Discharge Treated Effluent
to Fayetteville PWC's Rockfish Reclamation
Facility
Under this alternative, effluent from the Cedar Creek WWTP would be conveyed to the
recently constructed pump station and force main installed by DAK Resins and pumped
to a nearby lift station operated by the City of Fayetteville.
Stearns & Wheler,.PLLC
, Environmental Engineers and Scientists
3-5
DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Advantages include:
1. No capital improvements would be required for the wastewater treatment facility.
2. Allows DAK Resins to discontinue its NPDES permit.
Disadvantages include:
1. DAK Resins would be subject to surcharge fees, when effluent quality exceeds
the industrial pretreatment requirements.
2. Increased operational and maintenance costs associated with the pump station.
3. The solids generated would still need to be managed.
4. Site becomes less attractive for recruiting potential industries.
3.6 Alternative No. 6 — Land -based Disposal
Systems
Land based disposal systems such as a low-pressure pipe system, drip irrigation, mound
systems, and spray irrigation were also evaluated for both untreated wastewater and
treated wastewater. Direct application of raw wastewater using one of these land applied
disposal systems was not considered a viable solution, based on wastewater composition
and its potential detrimental impact on the receiving soil and groundwater. Consideration
was, however, given to using one of these disposal systems for land applying the treated
effluent from the existing wastewater treatment facility.
According to Cumberland County tax records, the DAK Resins owns approximately 68
acres of land along Cedar Creek Road. A significant fraction of the total acreage includes
manufacturing facilities, parking lots, access roads, administration buildings and the
WWTP, as shown on the aerial photograph — reference Figure 1.
Stearns & Wheler, PLLC
Environmental Engineers and Scientists
3-6 DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Fayetteville PWC recently performed an industrial wastewater survey to determine the
composition and concentrations of the treated effluent, as part of the industrial
pretreatment permitting process. A copy of this survey is provided in Appendix B. The
treated effluent exceeded the groundwater quality standards, as cited in section 15A
NCAC 02L, for arsenic, lead, nickel, and selenium. Although the concentrations for
these constituents were marginal, additional treatment would likely be required to comply
with the groundwater quality standards.
According to the County's soil survey map provided in Appendix D, the soil at the DAK
Resins facility is characterized as a sandy loam. The soil's assimilation capacity for
either land application or subsurface disposal systems depends on the following soil
parameters:
• Soil texture
• Soil structure
• Location of impervious areas
• Bulk density
• Seasonally saturated soils
Other important parameters include the depth to groundwater and the hydraulic gradient.
An assimilation rate of 1.0 gallon per day per square foot was applied based on the soil
texture and the low effluent suspended solids concentration (<20 mg/L). A disposal area
of approximately 11.5 acres would be required based on the permitted flow of 500,000
gallons per day. The 11.5 acres is, however, based on land applying wastewater 365 days
per year which will not be possible because of inclement weather conditions during some
times throughout the year. Assuming the facility could not land apply wastewater 30
days per year, the facility would need 15 million gallons of storage based on a permitted
flow of 500,000 gpd.
itStearns & Wheler, PLLC
Environmental Engineers and Scientists
3-7 DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

The existing site conditions, wastewater composition; and storage requirements required
for a land disposal system is cost -prohibitive and not practical. Therefore, land disposal
systems were eliminated from further consideration.
3.7 Alternative No. 7 — Wastewater Reuse
The use of treated effluent to reduce potable water use was also considered for process
water. Water needs are estimated at approximately 170,000 gallons per day, which is
significantly less than the 500,000 gpd of permitted capacity being requested.
The beneficial reuse of treated effluent for process water in the manufacturing process
was also considered. By reusing treated effluent within the manufacturing facility, the
quantity of potable water purchased from Fayetteville PWC could be reduced. When
comparing the quality of water needed for the manufacturing process to the quality of the
treated effluent, additional wastewater treatment systems would be necessary. This likely
includes ultra filtration arid reverse osmosis technologies. Based on the current costs
(capital and operations and maintenance) of such systems, this alternative is currently
considered cost prohibitive and not further evaluated.
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Environmental Engineers and Scientists
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DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Section 4 Opinion of Costs
4.1 Capital Costs
An opinion of probable capital cost for all alternatives is summarized below. Detailed
estimates for Alternative Nos. 2 and 4 are provided in Appendix E. Alternative Nos. 1, 3,
and 5 do not require initial capital investment to meet the current NPDES permit limits
and therefore, no costs are identified.
TABLE 4-1
OPINION OF PROBABLE CAPITAL COST
yi_ - - '�,-...::c.' ^-,":`-ems.. �:. . °l l("'G-
���� _ �. •.:• .Alterriatt�ex-�:; ���4 _
�' fJ !S
_.:O 'mion of.�rotialile,�_.
- /.4
S!%:
NaM.,
,. , .�jy..y..k ,�:!,.'DDsc�riptoriY= :n S -Y- •-,t
,f�v/wry:
Y
1
No Upgrades to Cedar Creek WWTP and
Maintain NPDES Permit
$0
2
Upgrade Cedar Creek WWTP and Maintain
NPDES Permit
$960 000
'
3
Discharge Untreated Wastewater to
Fayetteville PWC
$0
4
Upgrade Cedar Creek WWTP and Discharge
to Fayetteville PWC
$960 000
'
5
Discharge Treated Wastewater To
Fayetteville PWC
$0'
4.2 Operations 'and Maintenance Costs
An opinion of probable operations and maintenance costs for Alternatives No. 1, 2, 3, 4,
and 5 are summarized below. Detailed estimates are provided in Appendix F.
A. Steams & Wheler, PLLC
Environmental Engineers and Scientists
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DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

No.
1
2
3.
4
5-
TABLE 4-2
OPINION -OF PROBABLEO&M COS
Alternative
Description
No Upgrades:•to: Cedar• :Creek':WWTP : and:
Maintain NPDES Permit.
Upgrade. Cedar CreekWWTP and Maintain:.
NPDES Permit
Discharge Untreated . Wastewater
Fayetteville=PWC -:
Upgrade Cedar Creek WWTP:: and Discharge
to.Fayetteville PWG:.
Discharge Treated Wastewater- to. Fayetteville,
PWG :.
4.3. Pres.ei t::W®rth Analysis
Opinion of Probable
O&M Cost'
A 10-year. present .worth analysis was performed tocompare the present worth value of
thewastewater disposal alternatives based on the estimated initial capital investment
necessary toimplementthe alternative plus the estimated annual operations and
-maintenance costs. The life cycle cost _analysisis based on a 4 percent interest rate.
TABLE 4-3
PINION OF PROBABLE PRESENT WORTH COST
Opinion of
Cost
Alternative
No.1
No. 2
No. 3 -
No. 4
; No. 5
Capital Cost ::
$0:
$960,000..
^: $0.:1 ..:
$960,000 :..
:. $0...
O&M. Cost . -
$1,007,896
::$640,000:
$1,380,000
$.1,16.0,000
$1,392,896
Present Value
$8,200,000
$6,200,000
$11,200,000:.
'$9,240,000.: $1.1,300,000:
:.Stearns: & •eler;'PLLC
. Environmental Engineers and Scieriiists
DAK`Resins
Cedar. Creek Plant; North .Carolina
Engineering'Alteinatives Analysis

Section 5 Recommendation
Based on the alternatives evaluation, Alternative No. 2, which includes modifications to
the existing DAK Resins wastewater treatment plant and continued surface water
discharge to the Cape Fear River, is recommended. While some capital investment is
necessary to accomplish this, an upgraded plant whereby the current high costs associated
with aerating the wastewater and inefficient solids removalare addressed, a significant
reduction in operationsand maintenance cost can be achieved. Alternative 1, operating
the facility without upgrading is the second lowest cost alternative.
Stearns & Wheler, PLLC
L) UAL) Environmental Engineers and Scientists
5-1 DAK Resins
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

/, Stearns: & Wheler; PLLC.
L �' Environmental Engineers and Scientists - -

`3Stearns .&- Wheler; PLLC
1Environmental Engineers and Scientists

June 7. 2004
Mr. Craig Leite, Site Manager
DAK Resins, LLC
PO Box 1690
Fayetteville, North Carolina 28312
Michael F. Easley, Govemor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
•,r.
vI,1
Subject: NPDES Permit Modification - Name/Ownership Change
Permit NC0003719
DAK Resins - Fayetteville
Cumberland County
Dear Mr. Leite:
In accordance with your original request received December 29, 2003, the Division is
forwarding the subject permit modification. This modification documents the change in
name/ownership at the subject facility. It is the Division's understanding -that DAK Resins, LLC is
now the owner of the wastewater treatment plant, and subsequently the NPDES permit (NC0003719).
All other terms and conditions in the original permit remain unchanged and in full effect. This permit
modification is issued under the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U. S. Environmental Protection Agency
dated December 6, 1983.
In anticipation of the sale and removal of Monsanto, the Division of Water Quality initiated
certain conditions that the new permittee is required to perform. Part I, Condition A.(5.) of the permit
requires that:
• the new permittee submit proof of change of ownership along with the change in
name/ownership form (which DAK has submitted),
• the new permittee submit a new application for discharge, along with a major modification fee
of $860 outlining existing plans. future plans, and need for continued NPDES permit,
• the new permittee submit an Engineering Alternative Analysis in conjunction with the permit
application.
The above information should be submitted within 60 days of receipt of this letter. At this
time, DAK Resins should be compliant with Conditions A.(3.) .and A.(4.) for Outfall 002 (as well as the
other conditions specific to the other outfalls). The permit was originally structured with the
knowledge that Monsanto would be sold and the existing on -site industries needed an approved permit
to discharge. The Division of Water Quality decided to maintain the Monsanto permit at a reduced
flow after the period of shutdown at Monsanto. The Division of Water Quality was aware that
Monsanto was in contact with PWC Fayetteville and that the discharge may soon be routed to PWC
Fayetteville. In order to continue to maintain an NPDES permit to discharge, DAK Resins must clarify
and justify the need for flow and discharge of process wastewater. If this need cannot be justified to
the satisfaction of the Division, then the permit will not be reissued.
The name/ownership change has been completed. However, Condition A.(5.) has been
continued. as well as No. 4 in the Supplement to the Permit Cover Sheet. A new permit application
along with the Engineering Alternatives Analysis has been included with the permit.
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh. North Carolina 27699-1617
[phone]
FAX [phone]

Permit Number NC0003719
Mr. Leite
Page 2
If any parts. measurement frequencies or sampling requirements contained in this permit
modification are unacceptable to you, you have the right to an adjudicatory hearing upon written
request within thirty (30) days following receipt of this letter. Thit request must be a written petition
conforming to Chapter 150B of the North Carolina General Statutes, filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such
demand is made. this decision shall be final and binding.
This permit does not affect the legal requirement to obtain other permits which may be required
by the Division of Water Quality, the Division of Land Resources, Coastal Area Management Act, or any
other Federal or Local government permit that may be required. If you have any questions concerning
this permit, please contact Susan Wilson at (919) 733 - 5083, ext. 510.
Sincerely,
at(4„.J
Alan W. Klimek, P.E.
cc: Central Files
Fayetteville Regional Office, Water Quality Section
NPDES Unit
Ms. Penny Mahoney, DAK Resins, LLC
•

Permit Number NC0003719
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES.
DIVISION OF WATER QUALITY
,l
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
DAK Resins, LLC .
is hereby authorized to discharge wastewater from a facility located at
DAK Resins - Fayetteville
3468 Cedar Creek Road
Fayetteville
Cumberland County
to receiving waters designated as the Cape Fear River in the Cape Fear River Basin
in accordance with effluent limitations, monitoring requirements and other conditions set
forth in Parts I, II, III and IV hereof.
This permit shall become effective June 7, 2004.
This permit and authorization to discharge shall expire at midnight on October 31, 2006.
Signed this day June 7, 2004.
fa. -Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number NC00037 l 9
SUPPLEMENT TO PERMIT COVER SHEET
DAK Resins, LLC is hereby authorized to:
1. Continue to operate an existing 1.25 MGD wastewater treatment facility consisting
of flow equalization, spill basin, pH adjustment, oil skimming, comminute, dual
aeration basins, clarifier, parshall flume, sludge pump station, dual aerobic
digesters, aerated biosolids holding basin, biosolids drying beds and other
associated equipment located at DAK Resins, LLC, on NC Highway 53, south of
Fayetteville in Cumberland County.
2. Upon closure and clean-up of the Monsanto RoundUp plant, continue to operate
an existing 1.25 MGD wastewater treatment facility with a permitted discharge of
0.5 MGD consisting of flow equalization, spill basin, pH adjustment, oil skimming,
comminute, dual aeration basins, clarifier, parshall flume, sludge pump station,
dual aerobic digesters, aerated biosolids holding basin, biosolids drying beds and
other associated equipment located at DAK Resins, LLC, Fayetteville Plant, on NC
Highway 53, south of Fayetteville in Cumberland County.
3. Discharge water from said treatment works at the location specified on the
attached map into the Cape Fear River which is classified C waters in the Cape
Fear River Basin
4. Upon sale of the Monsanto Fayetteville facility, the new owner shall request a
modification to the NPDES permit and complete a new application for discharge in
accordance with special condition A. (5.) for an ultimate permitted flow of 1.25
MGD.
5. Discharge stormwater from the outfall specified on the attached map (and other
outfalls specified in the July 31, 1992 stormwater. permit:application) into the
Cape Fear River which is classified C waters in the Cape Fear River Basin.
Any other point source discharge to surface waters of the state is prohibited unless covered by another permit.
authorization or approval.
This permit does not relieve the permittee from responsibility for compliance
with any other applicable federal, state, or local law, rule, standard, ordinance,
order, judgement or decree.

L
atitude-
Longitude;
Quad #:
Stream Class:
Receiving Stream:
Permitted Flow:
34°58'08" Sub -Basin 03-06-15
78°46'58"
H23NFJCedar Creek, NC
C
Cape Fear Rives
L25 MGD (002) ani no limit (001)
asturc, Branch
Facility
Location
vf ' : -; ,--rcedatici *'��
DAK Resins, LLC
DAK Resins- Fayetteville Facility
NC0003719

Permit NC0003719
I_;
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date. of this permit and lasting until June 30. 2003. 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'
Flow
1.25 MGD :
Continuous
Recording
Influent or Effluent
Total Suspended Solids (TSS)
457.0 lb./day .
914.0 Ibiday
- 3/Week• '
Composite
Effluent
BOD5, 20°C (April 1— October 31)
191.0 IbJday
382.0 IbJday
3/week
Composite
Effluent
BOD5, 20°C (November 1— March
31)
382.0 IbJday
764.0 IbJday
3/week .
Composite
Effluent
COD
. 5000.0 IbJday
8000Ib./day
3/week
Composite
Effluent
NH3-N (April 1-October 31)
35.0 IbJday -
70.0 Ibiday
3lweek
Composite _
- Effluent .•
NHa-N (November 1-- March 31)
70.0 lb./day .
140.0 lb./day
3lweek '
Composite
Effluent
Fecal Coliform (geometric mean)
3/week •
. Grab
- Effluent
Total Nitrogen (NO2 + NO3 + TKN)•
- . Quarterly
Composite
Effluent
Total Phosphorus
Quarterly
Composite
Effluent - -
Glyphosate3
.2/month
Composite
Effluent
Total Residual Chlorine
3/Week
• Grab
Effluent
Acute Toxicity2
Quarterly
Composite
.Effluent
pH4
. 3lweek
Grab .:
• • Effluent.,.:
Dissolved Oxygen5
Weekly _
Grab : •
Effluent
Dissolved Oxygen5
(June 1 — September 30)
3/week
Grab
Upstream, : •
Downstream6.7
Temperature (2C)
Weekly
Grab
• Effluent •
Temperature (2C)
(June 1 — September 30)
3lweek
Grab
Upstream,
Downstream6.7
Conductivity
(June 1 — September 30)
_
3/Week
Grab
Upstream,
Downstream6.7
Notes:
1 Sample locations: Upstream - upstream 2 miles from outfall; Downstream - downstream. 100 yards upstream of Lock and
Dam #3. .
2 Whole Effluent Toxicity shall be measured by a P/F at 90% acute toxicity test using Fathead Minnow. Test shall be
conducted in February, May, August and November. See Part A. (5.). Samples for --toxicity testing shall be collected at the ,
combined outfall box located below outfalls 001 and 002.
3 Once cleanup of glyphosate production area is complete, Monsanto Company shall submit a letter to the Division giving
the shutdown and cleanup dates.- After this date -Monsanto shall sample for glyphosate six (6) additional times over the
course of three months. If these samples result in non -detects for glyphosate, glyphosate monitoring may be terminated.
If glyphosate is detected, the source should be identified and cleaned;.glyp hosate monitoring shall continue until such
point at which it is not detected in six (6) samples.
4 The pH shall not be less than 6.0 standard'units nor greater than 9.0 standard units.
5 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L. Effluent samples for dissolved
oxygen testing shall be collected at the combined outfall box located below .outfalls 001 and 002.
6 lnstream monitoring shall be conducted as follows: 3/week June 1 - September 30; 1 /week: October 1-May 31. •
7 As a participant in the Middle Cape Fear River Basin Association, the instream monitoring requirements as stated above
are waived. Should your membership in the agreement be terminated. you shall notify the Division immediately and the
instreasn monitoring requirements specified in your permit shall be reinstated.
There shall be no chromium, zinc. or aopperadded to the treatment system except as pre -approved
additives to biocide compounds or that which results from the normal degradation of piping and
equipment used in process units. •
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0003719
A. (2.) EFFLUENT LIMITATIONS AND
MONITORING gEQLREMENTS — FINAL
During the period beginning on the effective date of the permit and lasting until June 30. 2003.
authorized to discharge from outfall 002. Such discharges shall be limited and monitored by
ied below: the Permittee is
Effluent the Permittee as
L

Permit NC0003719
- A.(2.) Continued
Effluent
Characteristics
Limits
Monitoring Requirements
DAILY
MAXIMUM
(lbs./day)
MONTHLY
AVERAGE
(lbs./day)
MEASUREMENT
FREQUENCY t.
a
SAMPLE
•
SAMPLE
LOCATION'
Methyl Chloride
0.345
0.156
Annual
Grab
E
Methylene Chloride
0.162
0.073
Annual
Grab
E
Naphthalene
0.107.
0.040
Annual
Grab
E
Nitrobenzene
0.124
0.049
Annual
Grab
E
2-Nitrophenol
0.125
- 0.075
Annual
Grab
E
4-Nitrophenol
0.225.
0.131
Annual
Grab
E
Phenanthrene
0.107
0.040
Annual
•.. -Grab ,,
:- : E
Phenol
0.047
0.027
Annual
Grab
E .
Pyrene ..
0.122
0.045
Annual .
Grab
E
Tetrachloroethylene
0.102.
0.040
Annual
. Grab .
E
Toluene
0.145
0.047
Annual.
Grab
E
Total Chromium
• 5.034
2.017
Quarterly .
Grab
E
Total Copper
6.142
2.635
Quarterly
Grab
E
Total Cyanide
2.181
0.763
Quarterly .
Grab
E
Total Lead .
1.254
0.582
Quarterly
Grab
E
Total Nickel
7.233
3.071
Quarterly
Grab
E
Total Zinc •
Quarterly
Grab
E
1,2,4-Trichlorobenzene
0.254
0.124
Annual
Grab
E
1,1,1-Trichloroethane
0.098
0.038
Annual .
Grab
E
1,1,2-Trichloroethane
0.098
0.038
Annual
Grab
E
Trichloroethylene
0.098
0.038
Annual
Grab
E
Vinyl Chloride
0.487
0.189
Annual
Grab
E
Effluent
Characteristics
Limit
`; :::.:
Monitoring Requirements
- .. -.•, - -
DAILY;: .
MAXIMUM
MEASUREMENT
FREQUENCY'
SAMPLE
..
SAMPLE
LOCATION1
Total PAHs2
69.70
Quarterly
Composite
E
Hexachlorobenzene •- •
1.73
Quarterly
Composite
E
Notes:
1. Sample Location: E - Effluent, I - Influent
2. Total PAHs are comprised of Benzo(a)anthracene; Benzo(a) pyrene; 3,4-Benzofluoranthene;
Benzo(k)fluoranthene; Chrysene; Dibenz(a,h)anthracene and Indeno(I,2,3-ed)pyrnene.
Note: Composite samples must be refrigerated
•

Permit NC0003719
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
During the period beginning on July 1.12003 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
Flow
Total Suspended Solids (TSS)
BOD5, 20°C
COD
NH3-N (April 1-October 31)
NH3-N (November 1 - March 31)
Fecal Coliform (geometric mean)
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Total Residual Chlorine
Acute Toxicity2
pH3
Dissolved Oxygen4
Dissolved Oxygen4
(June 1- September 30)
Temperature ('C)
Temperature (2C)
(June 1- September 30)
Conductivity
(June 1- September 30) ...
Limits
Monthly Average. Daily Maximum
0.5 MGD "ppm
Monitoring Requirements
72.5 lb./day ( r, 235.7 lb./day 59
43.4 IbJday ip0 115.7Ib./day 26+
35.0 lbJday 70.0 lb./day
• 70.0 lbJday 140.0 lb./day
Measurement Sample
Frequency Type
Continuous Recording
?P►D Weekly
(aO Weekly
Weekly
Weekly
Weekly
Weekly
Quarterly
Quarterly
Weekly
Quarterly
Weekly
Weekly
3/week
Weekly
3/week
3/Week
Composite
Composite
Composite
Composite
Composite
Grab
Composite
Composite
Grab
Composite
Grab
Grab
Grab
• Grab
Grab
Grab
Sample Location'
Influent or Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent'
Effluent.
Upstrearn,
Dowristrear 5,6
Effluent
Upstream,
Downstreams.s
Upstream,
Downstreams.s
Notes:
1 Sample locations: Upstream - upstream 2 miles from outfall; Downstream - downstream. 100 yards
upstream of Lock and Dam #3.
2 Whole Effluent Toxicity shall be measured by a P/F at 90% acute toxicity test using Fathead Minnow. Test
shall be conducted in February. May, August and November. See Part A. (5.). Samples for toxicity testing
shall be collected at the combined outfall box located below outfalls 001 and 002.
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L. Effluent samples
for dissolved oxygen testing shall be collected at the combined outfall box located below outfalls 001 and 002.
5 Instream monitoring shall be conducted as follows: 3/week June 1 - September 30
1 /week: October 1-May 31.
6 As a participant in the Middle Cape Fear River Basin Association, the instream monitoring requirements as
stated above are waived. Should your membership in the agreement be terminated, you shall notify the
Division immediately and the instream monitoring requirements specified in your permit shall be reinstated.
There shall be no chromium, zinc, or copper added to the treatment system except as pre -
approved additives to biocide compounds or that which results from the normal degradation of
piping and equipment used in process units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
-

Permit NC0003719
A. (4.) EFFLUENT LINIITATIONS AND MONITORING REQIREMENTS - FINAL
During the period beginning on July 1. 2003 and lasting until expiration, the Permittee is authorized to discharge
from outran 002. Such discharges shall be limited and monitored by the Permittee as specified bel�w�
Effluent •
Characteristics
Limits
::. Monitoring Requirements
4 ..
5.
: .,.:_ .•
DAILY
MAXIMUM
(Ibs %day)
MONTHLY
AVERAGE
Ubs./day)
MEASUREMENT
FREQUENCY
• :. • .
SAMPLE
• '
. SAMPLE
LOCATION'
Acenaphthene
0.107
0.040
Annual
Grab"
E
Acenaphthylene
0.107
0.040
Annual
Grab
E
Acrylonitrile •
0.440
0.174
Annual _
Grab ,
E
Anthracene
- 0.107
0.040
Annual
Grab •
E
Benzene
0.247
0.067
Annual . '
Grab "
E
Benzo(a)anthracene
0.107
0.040
Annual
Grab
E
3,4-Benzofluoranthene
0.111
0.042
Annual
Grab
E
Benzo(k)fluoranthene
0.107
0.040
Annual
Grab
E
Benzo(a)pyrene
0.111
0.042
Annual
Grab"
E
Bis(2-ethylhexyl) phthalate
0.507 -
0.187
Annual •
Grab .
E
Carbon Tetrachloride
0.069
0.033
Annual
Grab
E
Chlorobenzene
0.051
0.027
Annual •
Grab
E
Chloroethane
0.487
0.189
Annual
Grab
E
Chloroform
0.084
0.038
Annual
Grab
E
2-Chlorophenol
0.178
0.056
Annual
Grab
E
Chrysene
0.107
0.040
Annual
Grab
E
Di-n-butyl phthalate
0.104
0.049
Annual
Grab
E
1,2-Dichlorobenzene
0.296
0.140
Annual
Grab
E
1,3-Dichlorobenzene
0.080
0.056
Annual
Grab
E
1,4-Dichlorobenzene
, 0.051
0.027
Annual
Grab
E
1,1-Dichioroethane
0.107
0.040
Annual '.= -
' Grab -
E
1,2-Dichloroethane
0.383
0.124
Annual
Grab
E
1,1-Dichloroethylene
0.045
0.029
Annual
Grab
E
1,2-trans-Dichloroethylene
0.098
0.038
Annual
Grab
E
2,4-Dichlorophenol
0.204
0.071
Annual
Grab
E
1,2-Dichloropropane., •
0.418
0.278
Annual
Grab
E
1,3-Dichloropropylene
0.080
0.053
Annual
Grab
E
Diethyl phthalate •
0.369
0.147
Annual
Grab
• E
2,4-Dimethylphenol
0.065
0.033
Annual
Grab
E
'Dimethyl phthalate
0.085
0.035
Annual
Grab
E
4,6-Dinitro-o-cresol
• 0.503
0.142
Annual
Grab
E
2,4-Dinitrophenol
0.224
0.129
Annual
Grab '
E
2,4-Dinitrotoluene
0.518
0.205
Annual
Grab
E
2,6-Dinitrotoluene
1.165
0.463
Annual
Grab
E
Ethylbenzene
0.196
0.058
Annual
Grab
E
Fiuoranthene
0.124
0.045
Annual
Grab
E
Fluorene _
0.107
0.040
Annual
Grab
E
Hexachlorobenzene
Annual
Grab
E
Hexachlorobutadiene
0.089
0.036
Annual
Grab
E
Hexachloroethane
0.098
0.038
Annual •
Grab
E

Permit NC0003719
A.(4.) Continued
Effluent
Characteristics
Methyl Chloride
Methylene Chloride
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
Phenanthrene
Phenol
Pyrene
Tetrachloroethylene
Toluene
Total Chromium
Total Copper
Total Cyanide
Total Lead
Total Nickel
Total Zinc
1,2,4-Trichlorobenzene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Vinyl Chloride
Limits
DAILY
MAXIMUM
(Ibs./day)
0.345
0.162
0.107
0.124
0.125
0.225
0.107
0.047
0.122
0.102
0.145
5.034
6.142
2.181
1.254
7.233
0.254
0.098
0.098
0.098
0.487
MONTHLY
AVERAGE
(Ibs./day)
0.156
0.073
0.040
0.049
0.075
0.131
0.040
0.027
0.045
0.040
0.047
2.017
2.635
0.763
0.582
3.071
0.124
0.038
0.038
0.038
0.189
Monitoring Requirements
.MEASUREMENT
FREQUENCY
Annual
Annual
Annual
Annual
Annual
Annual
Annual
Annual
Annual
Annual
Annual
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Anrrual
Annual
Annual
Annual
Annual
SAMPLE
Grab
Grab.
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
.Grab
Grab
Grab
Grab
Grab
SAMPLE
LOCATION'
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
Notes:
1. Sample Location: E - Effluent, I - Influent
Note: Composite samples must be refrigerated

Permit NC0003719
A. (5.) .SPECIAL CONDITION FOR TERMINATION OF MONSANTO DISCHARGE
The Monsanto Roundup plant portion of this discharge is expected to terminate within the
first half of 2002. The Monsanto Company will retain control over the utilities until such
time as the facility and utilities are purchased.
The allocation for this permitted discharge remains at 1.25 MGD. However, a new permit for
the discharge will be issued when all of the following take place:
• Proof of change. of ownership from Monsanto Company has beenfurnished. The
resulting name/ownership change form shall be submitted to the Division of
Water Quality.
• A new application for a discharge has been completed and submitted by the new
owner of the facility with a request for a major modification of the NPDES permit.
• The request for a major modification to NPDES Permit NC0003719 should
include the appropriate fee for such an action. •
• Completion of the application shall include a complete flow justification for the
proposed discharge and an Engineering Alternatives Analysis (EAA).
When all of the above actions are complete, the Division shall furnish new effluent limits
pages that are appropriate for the proposed discharge or set of discharges.
A. (6.) BIOCIDE CONDITION
The permittee shall not use any biocides except thosd approved in conjunction with the
permit application. The permittee shall notify the Director in writing not later than ninety
(90) days prior to instituting use of any additional biocide used in cooling systems which f'
may be toxic to aquatic life other than those previously reported to the Division of Water
Quality. Such notification shall include completion of Biocide Worksheet Form 101 and a
map locating the discharge point and receiving stream.
A. (7.) DETECTION LEVELS FOR.COMPLIANCE
If the discharge limitation of a given parameter is below quantitation limits, the measured
quantity for the purposes of a compliance evaluation is considered to be zero. Values that
report below quantitation level shall be deemed to be in compliance.
•

Perrnit NC0003719
A. (8.) ACUTE TOXICITY PASS/FAIT, PERMIT LINIIT (QUARTERLY)
The Permittee shall conduct acute toxicity tests on a uarterl basis 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 monito ing
shall
Minnow (Pimephales pro elas) 24 hour s atic test. The effluent cone ntrationh at wch there as a Fathead
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: Environmental, Sciences Branch
North Carolina ;Division of Water Quality
1621 Mail Service Center
Raleigh. N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made. •
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed
in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
Permittee will complete the information located at the top of the aquatic toxicity (A
facility name, permit number, pipe number. county, and the month/yearreport test formen notation
othe
f "
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at
the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing. this monthly test requirement will
revert to quarterly in the months specified above.
Should the Permittee fail to monitor during a month in which toxicity monitoring is required. then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above.
Should any test data from either these 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
il A. (9.) STORMWATER MONITORING REQUIREMENTS/Analytical. Monitoring
FINAL
During the period beginning on the effective date of the permit and lasting until June 30. 2003, the Permittee is
authorized to discharge from outfall(s) serial number 001 (Stormwater). Such discharges shall be limited and
monitored by the permittee as specified below:
STORMWATER
DISCHARGE
CHARACTERISTICS
•
LIMITS •
MONITORING REQUIREMENTS
Units
Cut-off
Concentration)
Measurement
Frequency2•
` Sample -
Type
Sample
Location3
Total Flow4
MG
Annual
SW-1
Total Rainfall4
Inches
Annual
-
SW-1
Event Duration'
Minutes
Annual
SW-1
Total Suspended
Solids
mg/L
100.00
Annual
Grab
SW-1
Nickel
,µg/L
789.00
Annual
Grab
SW-1
Lead
µg/L .
33.78
Annual
• Grab
SW-1
Di-n-butyl phthalate
mg/L -_
Annual
Grab
SW-1
Glyphosate
mq/L
Annual •
Grab
SW-1
Isopropylamine
mg/L
Annual
Grab
SW-1
Surfactants (MBAS)
mg/I -
100.0
Annual •
Grab .
SW-1
Notes: •
1. Cutoff -Concentration. For each parameter, the arithmetic mean of all analytical sampling results
collected during the first year of the permit shall be calculated for each individual .outfall and
compared to the cut-off concentrations listed. If the arithmetic mean is below the specified cut-off
concentration for a givenparameter, then the facility is not required to continue annual analytical
monitoring for that parameter at the outfall during the term of the permit unless a significant
change in facility operations or configuration occurs. If cut-off concentration results in
discontinued analytical monitoring at an individual discharge outfall, -the permittee is required to
maintain facility operations that ensure the continuation of stormwater runoff quality.
2. Measurement frequency.. Once per year. The facility must perform analytical sampling during the
first full year and last year of the permit term regardless of cut-off concentration conditions.
Analytical results from sampling.during the final year of the permit term must be submitted with
the permit renewal application. Failure to monitor storm events in accordance with the specified
frequency shall constitute a violation of this permit.
3. Sample Location. Samples to be collected at each stormwater discharge outfall (SW-1) located
north of the river water intake pump overflow and south of the sludge .drying beds.
4. For each sampled representative storm event the total precipitation, storm duration, and total flow
must be monitored. Total flow shall be•either: (a) measured continuously, (b) calculated based on
the amount of area draining to the outfall, the amount of build -upon (impervious) area, and the
total amount of rainfall, or (c) estimated by the measurement of flow at 20 minute intervals during
the rainfall event (not to exceed three hours).
For purposes of the stormwater sampling required in this permit, all samples shall be collected from a
discharge resulting from a representative storm event (See Parts A. (13) and A. (14.)).

Permit NC0003719
A. (10.)STORMWATER MONITORING RE
FINAL QUIREMENTS/Analytical Monitoring
During the period beginning on July 1, 2003 and lasting
until authorized to discharge from outfall(s) serial number 001 (St rmwatert ). Such discharges piration or shall be limited and
monitored by the permittee as specified below:
STORMWATER
DISCHARGE .
CHARACTERISTICS
Total Flow4
Total Rainfall4
Event Duration'
Total Suspended
Solids
Nickel
Lead
Di-n-bu I phthalate
Notes:
1. Cutoff Concentration. For each parameter, the arithmetic mean of all analytical sampl'
collected during the first year of the permit shall be calculated for each individual outfall and esults
compared to the cut-off concentrations listed. If the arithmetic mean is below the specified cut-off
concentration for a given parameter, then the facility is not required to continue annual anal
monitoring for that parameter at the outfall during the term of the permit unless a significant
change in facility operations or ,configuration occurs. If cut-off concentration results in analytical
discontinued analytical monitoring at an individual discharge outfall, the permittee is required to
maintain facility operations that ensure the continuation of stormwater runoff quality.
2. Measurement fret Once per year. The facility must perform analytical
saling during
first full year and last year of the permit term regardless of cut-off concentration conditions. the
Analytical results from sampling during the final year of the permit term must be submitted with
the permit renewal application. Failure to monitor storm events in accordance with the specified
frequency shall constitute a violation of this permit.
3. Sam le Location. Samples to be collected at each stormwater discharge outfall (SW-1) located
north of the river water intake pump overflow and south of the sludge drying
4. For each sampled representative storm event the total precipitationstorm duration, and total flow
must be monitored. Total flow shall be either: (a) measured continuously, (b) calculated based on
the amount of area draining to the' outfall, the amount of build -upon (impervious) area, and the
total amount of rainfall, or (c) estimated by the measurement of flow at 20 minute intervals during
the rainfall event (not to exceed three hours).
For purposes of the stormwater sampling required in this permit,
all samles discharge resulting from a representative storm event (See Parts A. (13) and A. (a411)be collected from a
).
Units
MG
Inches
Minutes
mg/L
µg/L
pg/L
m./L
LIMITS
Cut-off
Concentration1
100.00
789.00
33.78
%t
MONITORING REQUIREMENTS
Measurement
Frequency2
Annual
Annual
Annual
Annual
Annual
Annual
Annual
Sample
Type
Grab
Grab
Grab
Grab
Sample
Location3
SW-1
SW-1
SW-1
SW-1
SW-1
SW-1
SW-1

Permit NC00037.19 .
A (11). STORMWATER MONITORING REQUIREMENTS/ Qualitative Monitoring
Qualitative monitoring requires a -qualitative inspection of each stormwater outfall, regardless of
representative outfall status, for the purpose of evaluating the effectiveness of the Stormwater
Pollution Prevention Plan and assessing new sources of stormwatcr pollution. No analytical tests•are
required. Qualitative monitoring of stormwater outfall does not need to be performed during a
representative storm event.
Stormwater Discharge
Characteristics . •- •
Measurement. _ ,
Frequencyl.. :.
Sample
Location2 ..
Color
Semi -Annual
•SW-1
Odor
Semi -Annual
SW-1
Clarity
Semi -Annual
SW-1.
Floating Solids
Semi -Annual
SW-1
Suspended Solids
Semi -Annual
SW-1
Foam
,Semi -Annual
SW-1
Oil Sheen
Semi -Annual
SW-1
Other obvious indicators of stormwater pollution
Semi -Annual
SW-1 •
Notes:
1. Measurement Frequency. .The .first qualitative monitoring event during the term of the permit must
be performed during the initial analytical monitoring event. All subsequent qualitative monitoring
will be performed twice per year, once in the spring (April - June) and once in the fall (September -
November).
Sample Location: SW-1 Visual monitoring may be performed just inside the perimeter fence at a point
where no additional significant materials could reasonably enter the system as a result of facility -
operations.

Permit NC0003719
A. (12). STORMWATER SPECIAL CONDITION — OUTFALL
Representative outfall status has been granted to allow representative stormwater monitoring
at the manhole located north of the river water intake pump overflow and south of the slud
Should the facility configuration, drainage areas and activities, to. be perfonx—,
significantly altered, the'permittee shall notifyand/or stormwater outfalls e drying
ng bed
the Division in writing prior to implementation of said change
A. (13.) STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred
Plan. The Plan shall be considered public information in accordance with Part II. Section E.1
permit. The Plan shall be updated on an annual basis. The Plan shall include, at a min to as, the.
following items: 0. of this
minimum, the
a. Site Plan: The site plan shall provide a description of the physical facility and the ote
pollutant sources which may be expected to contribute to contamination of regulated
stormwater discharges. The site plan shall contain the following: P g potential
(1) A general location map (USGS quadrangle map, or appropriately drafted equivalent
map), showing the facility's location in relation to transportation routes and surface
waters, • and the name of the receiving water(s) to which the stormwater outfall(s)
discharges. If the discharge is to a municipal separate storm sewer system,
the
the municipality and the ultimate receiving waters; and accurate latitude and loname of
ng itude
of the point(s) of discharge must be shown.
(2) A narrative description of I
P storage practice, loading and unloading activities, outdoor
process areas. dust or particulate generating or control processes, and waste disposal
practices.
(3) A site map (or series of maps) drawn to scale with the distance legend indicating
location of industrial ;activities (including storage of materials, disposal areas, process
areas, and loading and unloading areas), drainage structures, drainage areas for each
outfall and activities occurring in the drainage area, building locations and impervious
surfaces, the percentage of each drainage area that is impervious. For each outfall, a
narrative description of the potential pollutants which could be expected to be present
in the regulated stormwater discharge.
(4) A list of significant spills or leaks of pollutants that have occurred at the facility during
the 3 previous years and any corrective actions taken to mitigate spill impacts.
(5) Certification that the stormwater outfalls have been evaluated for thepresence
stormwater discharges; The certification statement will be signed in accordance with
the requirements found in Part II, Section B.11.
b. Stormwater Management Plan:
The stormwater description of the materials managemen practic sanemployedtwhich lan Scontrol orhall a minimizezathe
exposure of significant materials to stormwater, including structural and -
or the
measures. The stormwater management plan, at a minimum, shall incorporate the followin :
non-structural
(1) A study addressing the; technical and economic feasibilityof g
operations and/or storage practices to eliminate or reduce exposure of materialsdand
processes to stormwater;. Wherever practicable the permittee should consider covering
storage areas, material handling operations, manufacturing or fueling operations to
prevent materials exposure to stormwater. In areas where elimination of exposure is
not practicable, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
i

Permit NC0003719
(2) A schedule to provide secondary containment for bulk storage of liquid materials.
storage of Section 313 of Title III of the Superfund Amendments and Reauthorization
Act (SARA) water priority chemicals,- or storage of hazardous materials to prevent leaks
and spills from contaminating stormwater runoff. If the secondary containment devices
are connected directly to stormwater conveyance systems, the connection shall . be
controlled by manually activated valves or other similar devices [which shall be secured
. with a locking mechanism) and any stormwater that accumulates in the containment
area shall be at a minimum visually observed 'prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be uncontaminated.
Records documenting . the individual making :the observation, the description of the
accumulated stormwater and the date and time of the release shall be kept fora period
of five years.
(3) A narrative description of Best Management Practices (BMPs) to be considered such as,
but not limited to, oil and grease separation. debris control, vegetative filter strips.
infiltration and stormwater detention or retention; where necessary. The need for
structural BMPs shall be based on the assessment of potential of sources contributing
significant quantities of pollutants to stormwater discharges and data collected through
monitoring of stormwater discharges.
(4) Inspection schedules of stormwater conveyances and controls and measures to be taken
to limit or prevent erosion associated with the stormwater systems.
c. Spill Prevention and Response Plan: The Spill Prevention :and Response Plan shall incorporate
a risk assessment of potential pollutant sources based on a materials inventory of the facility.
Facility personnel (or team) responsible for implementing the plan shall be identified in the
plan. A responsible person shall be on -site at all tithes during facility operations that have the
potential to contaminate stormwater runoff through spills or exposure of materials associated
with the facility operations.
d. Preventative Maintenance and Good Housekeeping. Program: A preventative maintenance
program shall be developed. The program shall document schedules of inspections and
maintenance activities of stormwater control systems, plant equipment and systems.
Inspection of material handling areas and regular cleaning schedules, of these areas shall be
incorporated into the program.
e. Training schedules shall be developed and training provided at a minimum on an annual basis
on proper spill response and cleanup procedures and preventative maintenance activities for all
personnel involved in any of the facility's operations that have the potential to contaminate
stormwater runoff. Facility personnel (or team) responsible for implementing the training shall
be identified in the plan.
f. The Stormwater Pollution Prevention Plan shall identify a specific position(s) responsible for the
overall coordination, development, implementation, and revision to the Plan. Responsibilities
for all components of the Plan shall be documented and position(s) assignments provided.
g. Plan Amendment: The permittee shall amend the Plan whenever there is a change in design,
construction, operation, or maintenance which has a significant effect on the potential for the
discharge of pollutants via a point source to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis. •
The director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying • the Plan to meet minimum requirements.
The permittee shall provide certification in writing (in accordance with Part III, Standard
Conditions; Section B.11.) to the Director that the changes have been made.

Permit NC0003719
h. Facility Inspections: Inspections of the facility and all stormwater systems shall occur at
minimum on a semiannual schedule. once in the fall (September- November) and once during
the spring (April - June). The inspection and any subsequent maintenance activities performed
shall be documented, recording date and time of inspection, individual(s) making the inspection
and a narrative description:of the facility's stormwater control systems, plant equipment and
systems. Records of these: inspections shall be incorporated into the Stormwater Pollution
Prevention Plan.
' Visual monitoring as required in . A (4) Stormwater Monitoring .Requirements/Qualitative
Monitoring shall be performed in addition to facility inspections.
1. Implementation: Implementation of the Plan shall include documentation of all monitoring.
measurements, inspections; maintenance activities and training provided to employees,
including the log of the sampling data. Activities taken to implement BMPs associated with the
industrial activities, including vehicle maintenance activities must also be recorded. All
required documentation shall be kept on -site for a period of five years and made available to
the Director or his authorized representative immediately upon request.
A. (14) STORMWATER MINENIU1VI MONITORING AND REPORTING
REQUIREMENTS
Minimum monitoring and reporting requirements are as follows unless otherwise approved in writing
by the Director of the Division of Water Quality:
a. If a facility has multiple discharge locations with substantially identical stormwater discharges
that are required to be sampled, the permittee mayarges
outfall status. If it is established that the stormwaerr discharges Dare substantiaor for lly identical
performed at a reduced number of outfalls.
and the permittee is granted representative outfall status, then sampling requirements may be
b. Visual monitoring for color, odor, solids, foam, outfall staining, visible sheens and dry weather
flow shall be performed at all stormwater discharge outfall locations. All visual monitoring
shall be documented and records maintained with the Stormwater Pollution Prevention Plan.
The initial visual monitoring event shall be performed simultaneously with the first analytical
monitoring event and documentation of only this initial visual monitoring event shall be
submitted along with the required analytical monitoring submittal.
c. For purposes of the stormwater sampling required in this permit, all samples shall be collected
from a discharge resulting from arepresentative storm event (See definitions in Part II, Section
A). Failure to monitor storm events in accordance with the specified frequency shall constitute
a violation of this permit. If the stormwater runoff is controlled by a detention pond, the
following sampling requirements shall apply:..
(1) If the detention pond detains the runoff generated by one inch of rainfall for 24 hours.
visual observations for color, foam, outfall staining, visible sheens and dry weather flow
are required, but analytical sampling shall not be required.
(2) If the detention pond discharges only in response to a storm event exceeding a 25-year,
24-hour storm, the pond shall be considered a non -discharging stormwater control
system and not subject to NPDES requirements, unless the discharge causes a violation
of water quality standards.
d. Samples analyzed in accordance with the terms of this permit shall be submitted on forms
approved by the Director no later than January 31 for the previous year in which sampling was
required to be performed.

Permit NC0003719
e. Analytical results from sampling during the final year of the permit term shall be submitted
with the permit renewal application.
f. This permit regulates stormwater discharges associated with industrial activity. Non-
stormwater discharges which shall be allowed in the stormwater conveyance system are:
(1) All other discharges that are authorized by an NPDES permit.
(2) Foundation drains, air -conditioner condensate without added chemicals: springs,
waterline and fire hydrant, water from footing drains, flows from riparian habits -and
wetlands, fire -fighting training and fire system testing.
(3) Discharges resulting' from fire -fighting.
g.
If the storm event monitoredandreported in accordance with this permit coincides with a non-
stormwater discharge, the permittee shall separately monitor -and report all parameters as
required under the non-stormwater portion of this permit and provide this information with the
stormwater discharge monitoring report.
A. (15.) STORMWATER DEFINITIONS
1. Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs
may take the form of a process, activity, or physical structure.
2. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single
above ground storage container having a capacity of greater than 660 gallons or with multiple above
ground storage containers located in close proximity to each other having a total combined storage
capacity of greater than 1,320 gallons.
3. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is
not a land treatment facility, a surface impoundment, an injection well, a hazardous waste long-term
storage facility or a surface storage facility.
4. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any
pipe, ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be
discharged to waters of the state.
5. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded,by at least
72 hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm
event may contain up to 10 consecutive hours of no precipitation. For:example, if it rains for 2 hours
without producing any collectable discharge, and then stops, a sample may be collected if a rain
producing a discharge begins again within the next 10 hours.

Permit NC0003719 .
6. Secondary Containment
Spill containment for the contents of the single largest tank within the containmen
plus sufficient freeboard to allow for the 25-year, 24-hour storm event. t structure
7. Section 313 Water Prioritv.Chemical
A chemical or chemical category which:
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund
Amendments and Reauthorization Act (SARA) of 1986,.also titled the Emergency
Planning and Community Right -to -Know Act of 1986:
b. Is present at or above threshold levels at a facility subject to SARA title III, Section 313
reporting requirements; and
c. That meet at least one of the following criteria:
(1) Is listed in Appendix D of 40 CFR part 122 on either Table II (organic priority
pollutants), Table III (certain metals, cyanides, and phenols) or Table IV (certain
toxic pollutants and hazardous substances);
(2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the CWA
at 40 CFR 116:4; or .
(3) Is a pollutant for which EPA has published acute or chronic water quality criteria.
8. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents,
and
plastic pellets; finished materials such as metallic products; raw materials used in food processings or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant ito section 313 of Title III of SARA; fertilizers; pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
9. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 117.21) or section
102 of CERCI.A (Ref: 40 CFR 302.4).
10. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying storrnwater and
which is directly related to manufacturing, processing or raw Material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in 40
CFR 122.26(b)(14). The term does not include dischargesfrom facilities or activities excluded from the
NPDES program.

Stearns: & Wheler; PLLC
Environmental Engirieers and, Scientists

Industrial User Wastewater Survey
& Permit Application
COVER PAGE
Company Name: DAK RESINS, LLC
Name of responsible person on site at the facility authorized to represent the
company in official dealings with the Sewer Authority and/or the City.
Stanley Carter .
Name of alternative on site person familiar with the day to day operations,
environmental permitting requirements, monitoring, record keeping, and
data management..
Anthony Hudson ' -
Tit1e: Service Complex Manager _
Years with firm: 1
Title SHE Leader
Years with firm
Phone # [phone]
Fax # [phone]
Phone # [phone]
Fax # [phone]
Physical street address of facility
3468 Cedar Creek Road
Official mailing address, if different. Note if same. •
3216 Cedar Creek Road
City: Fayetteville
State: NC
Zip: 28312
City: Fayetteville
State: NC
Zip: 28312
The information provided by you on this questionnaire serves two functions: _
1. The information is used to determine if your facility needs an Industrial User Pretreatment
Permit (IUP) for the discharge of wastewater to the local sewer.
2. If an Industrial User Pretreatment Permit (IUP) is required, this survey serves as the
application for an Industrial User Pretreatment Permit (IUP).
Requests for confidential treatment of information provided on this form shall be governed by procedures specified in 40 CFR
Part 2. In accordance with Title 40 of the Code of Federal Regulations Part 403, Section 403.14 and the Local Sewer Use
Ordinance (SUO), information and data provided in this questionnaire which identifies the content, volume and frequency of
discharge shall be available to the public without restriction.
This is to be signed by an authorized official of your firm, as defined in the Local Sewer Use Ordinance or the NC Model
Sewer Use Ordinance, Section 1.2, after completion of this form.
I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate
the information submitted. Based .upon my inquiry of the person or persons who manage the .system, or those
persons directly responsible for gathering the infonnation, the information submitted is, to the- best of my
knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting
false information, including the possibility of fine and/or imprisonment for knowing violations.
Signature of Authorized Representative Date
listed above (seal if applicable)
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Interact Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 1 of 20

Industrial User Wastewater Survey
& Permit Application
1. Provide a brief narrative description of the type of business, manufacturing processes, or
service activities your; firm conducts at this site.
The DAK Resins plant manufactures polyester pellets that are used in the plastic container market. The manufacturing process is „:
completely automated and is controlled from a central control room. Raw materials and catalysts are continuously fed into a seric
of continuous polymerization vessels to 'produce polyester resin. The resin is extruded and cut into 1/8" cube pellets. The pellets
then undergo another heat treatment phase to produce the desired polymer properties. The finished product is shipped via the
railroad to customers.
The DTF plant consists of 10, essentially identical, batch production lines for making polyester resins (PET). The PET
manufacturing process is a two step process. The first step involves the esterification ofdimethyl terephthalate and ethylene
glycol, with catalyst and additives to form monomer. Once the esterification process is complete, the monomer batch is
transferred to the polymerization reactor. Upon completion of polymerization, the batch is extruded through a die head to a chip cutter/ dryer. PET chips are then transferred to a blending silo and processed through a screener. The fmal product is transferred _
to a finish silo from which they are loaded into shipping containers (railcars, bulk trailers, super sacks, oversea containers, or
boxes) to be sent to customers.
DTF batch sizes are approximately 5000 lbs., and the total processing time for a batch is approximately 8 hours (4 hours in the
esterifier and 4 hours in the polymerizer). Esterification and polymerization / chip cutting run in parallel on each line.
The DAK Services Complex provides utilities to the DTF and DAK Resins facilities at the Cedar Creek site. DAK Services
complex provides steam, cooling water, chilled water, potable water, and accepts wastewater from DTF and DAK resins facilitie:•,
L
2. List the primary products produced at this facility:
DAK Resins:
DTF:
DAK Utilities:
Polyethylene Terephthalate (PET) in the form of chips.
Polyethylene Terephthalate (PET) in the form of chips.
Utilities including Cooling Water, Steam, Chilled Water, and Treated Wastewater
3. List raw materials and process additives used:
DAK Resins: Raw Materials: Ethylene Glycol
Terephthalic Acid
Process Additives: Antimony Trioxide
Cobalt Acetate
Diphenyl
Diphenyl Oxide
Phosphoric Acid
Phosphorous Acid
PH Adjustment: Caustic — Potassium Hydroxide
DTF: Raw Materials: Ethylene • Glycol
Diinethyl Terephalate
Diethylene Glycol
Primary Additives: Antimony Triacetate
Antimony Oxide
Cobalt Acetate
Magnesium Acetate
Phosphoric Acid
Trimethyl Phosphate
Barium Sulfate
China Clay
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 2 of 20 L

Industrial User Wastewater Survey
& Permit Application
Silica
Titanium Dioxide
DAK Services Complex:
Raw Materials: None
Additives/ Other:Acetic Acid
Anhydrous Ammonia
Chemtreat P898L
Chemtreat P899L
Diesel Fuel No. 2
Ethylene Glycol
Fuel Oil No. 2
Fuel Oil No. 6
Gasoline
Muriatic Acid
Nalco 8306 Plus
Phosphoric Acid
Propane
Sodium Chloride
Sodium Hydroxide
Sodium Hypochlorite
Ultrion 8185 Clarification Aid
4. Are biocides added to any water discharged to the POTW, if yes
describe:
Yes
No
5. Describe weekly production schedule, including shifts worked per day, employees per
shift, and primary operation during shift.
X
DAK Resins: The plant operates 24 hours a day, 365 days a year. There are approximately 50 day employees that work form
7:45 am until 4:15 pm Monday through Friday. In addition, there are 4'shifts consisting of 7 employees each. The shift
employees work a rotating shift schedule. Each day is covered by two shifts , one working from 7 am to 7 pm and the other
working from 7 pm to 7 am. The site also employees contract workers. There are 13 permanent contract workers that work 4-10
hour shifts (Monday through Thursday.) During plant shut -downs, the number of contract workers increases.
DTF: The DTF plant operates 24 hours per day, 365 days a year. The plant operates on a 12 hour shift basis with approximate':
10 employees per shift. There are approximately 77 total plant employees. The employees that do not work on a shift (about 37)
work from 7:45 am to 4:15 pm providing support to the production operations.
DAK Services Complex: The DAK Services Complex operates 24 hours a day, 365 days a year. The plant operates on a 12 hot
shift basis with approximately 4' employees per shift. In addition, there are employees that work from 7:30 — 4:30 Monday
through Friday. The total number of employees at the plant is approximately 25.
6. Production process is: Check, if all continuous
Check, if all batch
If both please enter, % continuous = % Batch =
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\L,ocal Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97 Page 3 of 20
67%
(100 %DAK)
33%
(100 % DTF)

Industrial User Wastewater Survey
& Permit Application
7. Does production vary significantly (+- 20 %) by season. Describe.
Yes
No
x
8. Are any significant (+- 20 %) changes in production that will affect wastewater discharge expected in
the next 5 years. If yes, please describe.
Yes
No
The business plan for the DAK Americas resins plant calls for an expansion within the next 5 years. The expansion
project has not been authorized at this time, but DAK would like to have it considered in the PWC long term planning
9. List all current waste haulers. Give name, address, phone numbers, volume and materials hauled off.
1. Omni- Giant Resource
Recovery
2. Waste Management
3. RINECO
4. Waste Management
5. Safety-Kleen Systems
6. Sampson County Landfill
7. Safety-Kleen Systems
755'Industrial Rd., Sumter, SC 29151
Lab,Solvents/ Methylene Chloride — 385 lbs. liquid
Waste Paints —190 lbs liquid
Waste Oils — 567 lbs liquid
Contaminated Absorbal —15,092 lbs Solid
Ethylene Glycol Sludge — 28,200 lbs Liquid
Phenol/ TCE Solids — 379 lbs Solid
Nalsperse — 128 Liquids
Lab'Solvents/ Phenol TCE —1,053 lbs
4201 Distribution Dr., Fayetteville, NC 28301— [phone]
Non -Hazardous Waste — (Trash)
Benton, Arkansas [phone]
Liquid and Non -Hazardous wastes for fuel blending — 50,000 lbs annually
Hazardous waste liquid — 600 lbs annually
Kernersville, NC [phone]
Non' Hazardous still bottoms —145,000 lbs annually
Smithfield, Kentucky [phone]
Liquid and Solid Non -Hazardous wastes for fuels blending — 40,000 lbs annually
Roseboro,.NC [phone]
Trash—133,000lbs annually
St. Paul, NC [phone]
Used Oil — 3200 lbs annually
10. Attach a copy of laboratory analyses performed in the last year on the wastewater discharge(s) from
your facilities. Summarize data on the attached Data Suinmary Form
11.
12.
Attached
Attach sketch or schematic showing sampling points and all connections to the sewer.
PFD provided
Complete the Wastewater Pollutants Checklist attached to this Survey.
Attached
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 4 of 20

Industrial User Wastewater Survey
& Permit Application
13. Do you have, or have you ever applied for, been issued, or been denied an NPDES
permit to discharge to the surface waters or storm sewers of North Carolina? If yes, list
all other NPDES permits, permit numbers, dates, and names used to apply for them, or
reason denied. -
Dupont Tejiin Films: NCS000056
DAK Services Complex: NC0003719
Yes
No
14. Do you have, or have you . ever applied for or been . issued an Industrial User
Pretreatment Permit (IUP) to discharge wastewater to, the sewer collection system. If
yes, list all other IUP permits, permit numbers, dates, and names used to apply for them.
Yes
No
15. Do you have, or have you ever applied for or been issued any other Environmental
Permits (for example; air; RCRA, groundwater, stormwater, general, Non -Discharge,
septic tank, etc.). If yes, list all other permits, permit numbers, dates, and names used to
apply for them.
Air Quality , 08907R2, 10/11/01, Dupont Teijin Films
Air Quality, 04051 R29, DAK Resins
Air Quality, 04319T18, DAK Services Complex
EPA ID No., NCD990714479, 10/24/01, Dupont Teijin Films
Non -Discharge Permit, W0003842, 11/16/90, ICI Americas
Yes
No
16. Is a Spill Prevention Control and Countermeasure (SPCC) Plan prepared for this
facility?
17. Is a Spill /Slug Control Plan required by the POTW, prepared for this facility?
18. Do you have any underground storage tanks at your facility? If yes, list contents and
volume of each tank.
x
x
Yes
No
Yes
No
Yes
No
X
X
X
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 5 of 20

Industrial User Wastewater Survey
& Permit Application
19. Do you have any above ground storage tanks at your facility? If yes, for each tank, list
the contents, volume, whether the tank has any spill prevention or containment
devices, such as dikes, and procedures for draining any containment devices.
Yes
# of Tanks
No
61
Tank Description
,Contents
Volume
Comments
Dowtherm Storage Tank *
Dowtherm A
26,580 Gallons
Diked Area
OSC Rentention Tank*
Wastewater
31,125 Gallons
Diked Area
Caustic Tank *
Sodium:Hydroxide
5834 Gallons
Diked Area
Ethylene Glycol Tank
(NGT) **
Ethylene Glycol
370,000 Gallons
Diked Area
Ethylene Glycol Tank
(PGT) **
Ethylene Glycol
370,000 Gallons
Diked Area
Methanol (CMT) ** -
Methanol
530,000 Gallons
Diked Area
Dowtherm A (Dirty) **
Dowtherm A
27,500 Gallons
Diked Area
Dowtherm A (Clean)**
Dowtherm A
10,000 Gallons
Diked Area
Ethylene Glycol Tank
(RGT) **
Ethylene Glycol
93,000 Gallons
Diked Area
Ethylene Glycol Tank
(MGT) **
Ethylene Glycol
6,000 Gallons
Diked Area
Ethylene Glycol Tank
(FGT) **
Ethylene Glycol
3,100 Gallons
Diked Area
No. 2 Fuel Oil Storage**
No. 2 Fuel Oil
300,000 Gallons
Diked Area
Dimethyl Terephthalate
Tank **
Dimethyl Terephthalate
1
300,000 Gallons
Diked Area
Gasoline Storage Tank **
Gasoline
500 Gallons
Double Containment
Wall
Ethylene Glycol Storage
Tank (CGS) **
Ethylene Glycol
2,500 Gallons
Diked Area
Methanol (CMS) **
Methanol
2,500 Gallons
Diked Area
Diethylene Glycol (DTF)
**
Diethylene Glycol
14,000 Gallons
Diked Area
Diethylene Glycol (DAK)
**
Diethylene Glycol
51,700 Gallons
Diked Area
Ethylene Glycol
(WGT)**
Ethylene Glycol
14,600 Gallons
Diked Area
Ethylene Glycol
(CGT)**
Ethylene Glycol
164,000 Gallons
Diked Area
Still Bottom Residue
(WS) **
Ethylene Glycol Residue
14,600 Gallons
Diked Area
Large Equalization Tank
A
Wastewater
660,500 Gallons
Large Equalization Tank .
B
Wastewater
660.500 Gallons
# 6 Fuel Oil Storage Tank
# 6 Fuel Oil
1,500,000 Gallons
# 6 Fuel Oil Stora . e Tank
# 6 Fuel Oil
200,000 Gallons
Diesel Storage
# 2 Fuel Oil
1,000 Gallons
Gasoline Storage
<Gasolin'e
1,000 Gallons
Demineralizer
Dimineralized Water
3,000 Gallons
Salt Tank #5
Salt Water
684 Gallons
Salt Tank #6
Salt Water
684 Gallons
Tank Description
, Contents
Volume
Comments
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 6 of 20
r--

Industrial User Wastewater Survey
& Permit Application
Salt Tank #7
Salt Water
684 Gallons
Salt Tank #8
Salt Water
684 Gallons
Salt Tank #9 •
Salt Water
684 Gallons
Water Softening Tank #5
Soft Water
1000 Gallons
Water Softening Tank #6
Soft Water
1000 Gallons
Water Softening Tank #7 -
. Soft Water
1000.Gallons
-
Water Softening Tank #8
Soft Water
1000.Gallons
Water Softening Tank #9
Soft Water
1000 Gallons
Neutralization Tank
Water, Sodium
Hydroxide, Sulfuric Acid
20,000 Gallons
Demineralized Water
Tank #1
Demineralized Water
20,000 Gallons
Demineralized Water
Tank #2
Demineralized Water
30,000 Gallons.
Demineralized Water
Tank #3
Demineralized Water
30,000 Gallons
Chilled Water Make-up
Tank
Chilled Water
15,000 Gallons
Deaerator
Water, Steam,
Compressed Air
30,000 Gallons
Knockdown Tank .
Compressed Air,
Condensate
500 Gallons
Chemical Storage Tank
#1720 Boiler Feed Water
1450 Gallons
Chemical Storage Tank
#1802 Corrosion
Inhibitor
1500 Gallons
Chemical Storage Tank
#7200 Boiler Feedwater
Treatment
1500 Gallons
Blow Down Flash Tank
Water,. Steam,
Compressed Air
500 Gallons
Propane Tank
Propane
1000 Gallons
Domestic Water Tank #1
.Water from PWC
250,000 Gallons
Domestic Water Tank #2 .
Water from PWC
250,000 Gallons
North Caustic Tank
. Sodium Hydroxide
8000 Gallons
South Caustic Tank
Sodium Hydroxide
9,500 Gallons
North Diesel Storage
Tank
# 2 Fuel Oil
1000 Gallons
South Diesel Storage
Tank
#2 Fuel Oil
1000 Gallons
Chemical Storage Tank
8306 Cooling Water
-Corrosion Inhibitor
1000 Gallons
Chemical Storage Tank
8300 Disperant and scale
inhibitor
1450 Gallons
Chemical Storage Tank
.7342 Chlorine Enhancer
& Biodispersant
1000 Gallons
Oil Skimmer Tank #1
Recovered Oil
1000 Gallons
Oil Skimmer Tank #2
Recovered Oil
1000 Gallons
* Denotes a DAK Resins Tank **Denotes a DTF Tank
No asterisk Denotes DAK Services Complex
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 7 of 20

Industrial User Wastewater Survey & Permit Application co)0.
PART II, Water Supply, Use, & Disposal Worksheet:
1.
2.
3.
4.
5.
6.
7.
8.
9.
Water Used for:
(DAK Resins, DTF,
DAK Services combined)
Water
Source(s)
Avg.
gal/day
Max.
gal/day
Measure
.c
w
Disposal
Method(s)
Avg.
gal/day
Max.
gal/day
Measure 1
I
Estimate
Process water
Washdown water
Water into product
Air Quality Permitted_ _units_ -
Domestic - toilets, drinking, cafe
Cooling water, Process NON -Contact
Boiler / Cooling tower blowdown
Cooling water, HVAC
Other: Condensate
Stonnwater
Process Generated Water
(see Source List below)
(see Disposal List below)
1
65,660
109,100
X
2
65,660
109,100
1
2,000
3,500
X
2
2,000
3,500
-
- -
--- .--
- -
- - -
---- __ --
-
1
4,100
5,900
X
2
4,100
5,900
1
50,000
60,000
X
2
50,000
60,000
1
2,880
4,320
X
2
2,880
4,320
X
1
28,620
50,000
209,680
100,000
X
X
2
2
28,620
50,000
209,680
100,00
X
X
Totals =>
203,260
49,500
Totals =>
203,260
492,500
Typical Water Sources:
1. City / Public supply
2. Private wells, drinking
3. Groundwater remediation wells
4. Private ponds
5. Surface waters of NC, please identify
6. Include others if applicable
c©4"D
,b0 ✓lam 2..
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Possible Water Disposal Methods
Sanitary sewer, with pretreatment
Sanitary sewer, without pretreatment
3. Storm sewer
4. Surface waters of NC
5. Evaporation
6. Land applied
7. To groundwater
8. Septic Tank
9. Waste Haulers (identify)
10. Water into Product
11. Include others, if applicable
Page 8 of 20
Tr - Fame

• PART III, PRETREATMENT FACILITIES:
Are there any pretreatment devices or processes used for treating wastewater before being
discharged to the sewer? Check all that are present, and describe.
1. Flow equalization
2. Activated Carbon
3. Activated Sludge
4. Air Stripping
5. Centrifugation
6. Chemical Precipitation
7. Chlorination
8. Cyanide Destruction
9. Cyclone
10. Dissolved Air Floatation
11. Filtration
12. Flocculation
13. Grease Trap
14. Grit Removal
15. Ion Exchange
16. Neutralize, pH adjust
17. Other Biological Treatment
18. Ozonation
19. Reverse Osmosis
20. Screening
21. Sedimentation
22. Septic Tank
23. Silver Recovery
24. Solvent Separation
25. Spill protection
List any others.
Yes
Yes.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No pretreatment facilities =>
Aerated equalization =>
NON -Aerated equalization =>
Total volume of equalization (million gal.) _>
X
X
X
X
X
X
X
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Yes
Yes
Yes
7.8
Describe any, if present.
DAK Resins OSC Column
DAK Services Complex
DAK Services Complex
DAK Services Complex
DAK Services Complex
DAK Resins
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page • 9 of 20

PART IV, CATEGORICAL INFORMATION:
1. When were operations started at this facility
Facility start up date
2. List all Standard Industrial Classification (SIC) codes for your facility. These may be
found on. State Unemployment forms, tax forms, accounting records, or from the
Chamber of Commerce.'
DAK Resins
DAK Services Complex
J1967
2821
4939
3. Has this facility ever been considered a Categorical Industrial User (CIU) as described
by the Code of Federal, Regulations.(40 CFR)?
If yes, give complete 40 CFR number =>
OCPSF, Organic Chemicals, Plastics and Synthetic Fiber Manufacturing
No
4. Are any other facilities' owned and/or operated by your company permitted as
Categorical Industrial Users (CIUs) as described by the Code of Federal Regulations
(40 CFR)?
If yes please give name(s), location, and 40 CFR number. Yes
No
40 CFR 414
Subpart D
x
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK141E08544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 10 of 20

-PART IV, CATEGORICAL INFORMATION:
(continued)
5: Check any activities listed below that are performed at your facility:
Check
40 CFR#
Check
40 CFR#
below
Industrial Activity
below
Industrial Activity
467 Aluminum Forming
427 Asbestos Manufacturing
461 Battery Manufacturing .
431 Builders paper & board mills
407 Canned & preserved fruits & veg.
408 Canned & preserved seafood
458 Carbon black Manufacturing
411 Cement Manufacturing
434 Coal Mining
465 Coil Coating
468 Copper Forming
405 Dairy products processing
469 Electrical, electronic components
413 Electroplating
457 Explosives Manufacturing
412 Feedlots
424 Ferro allay Manufacturing
418 Fertilizer Manufacturing
464 Foundries, Metal Mold & Casting
426 Glass Manufacturing
406 Grain mills
454 Gum & Wood Chemicals Mfg.
460 Hospitals
447 Ink formulating
415 Inorganic chemical Manufacturing
420 Iron & Steel Manufacturing
425 Leather Tanning & Finishing
432 Meat products
433 Metal finishing
464 Metal molding and casting
436 Mineral mining and processing
471 Nonferrous Metal, Form & Powders
421 Nonferrous Metals Manufacturing
414 OCPSF, Organic Chemicals, Plastics,'.
& Synthetic Fiber Manufacturing
435 Oil & gas extraction
440 Ore mining and dressing
446 Paint formulating
443 Paving and roofing materials Mfg.
455 Pesticide Manufacturing
419 Petroleum Refining
439 Pharmaceutical Manufacturing
422 Phosphate Manufacturing
459 Photographic supplies
463 Plastics molding and forming
466 Porcelain enameling
430 Pulp, paper, and paperboard
428 Rubber Manufacturing
417 Soap & Detergent Manufacturing
423 Steam Electric power Generation
409 Sugar processing
410 Textile Mills
429 Timber products processing
Others
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 11'of 20

Wastewater Pollutant Checklist
Chemical Name
EPA
Storet
Check if
Present at
Check if
Absent at
Check if
Present in
Check if
AAisent in
Concentration in
Discharge, if
Code
Facility
Facility
Discharge
Discharge ..
Known
(mg/1)
Acid Extractable Organics,
2-Chlorophenol
34586
X
X
2,4-Dichloronhenol
34601
X
X
2,4-Dimethvlohenol
34606
X
X
2.4-Dinitronhenol
34616
X
X
2-Methyl-4,6-dinitronhenol
34657
X
X.
4-Chloro-3-methvinhenol
34452
X
X
2-Nitrovhenol
34591
X
X
4-Nitrophenol
34646
X
X
Pentachloronhenol
39032
X
X
Phenol
34694
X
0.26
2.4,6-Trichloronhenol
34621
X
X
Base Neutral Ortanics
1,2,4-Trichlorobenzene
34551
X
X
1,2-Dichlorobenzene
34536
X
X
1,2-Dinhenvlhvdrazine
34346
X
X
1,3-Dichlorobenzene
34566
X
X
1,4-Dichlorobenzene -
34571.
X
X
2.4-Dinitrotoluene
34611
X
X
2,6-Dinitrotoluene
34626
X
X
2-Chloronaphthalene
34581
X
X
3,3-Dichlorobenzidine
34631
X
X
4-Bromophenyl phenyl ether
34636
X
X
4-Chlorophenyl phenyl ether
34641
X
X
Acenaphthene
93405
X
X
Acenaphthylene
34200
X
X
Anthracene
34220
X
X
Benzidine
39120
X
X
Benzo (a) anthracene
34526.
X
X
Benzo (a) pyrene .
4247
X
X
Benzo (b) fluoranthene.
34230
X
X
•
Benzo (ghi) perylene
34521
X
X
Benzo (k) fluoranthene
34242
X
X
Bis(2-chloroethoxy) methane
34278
X
X
Bis(2-chloroethyl) ether
34273
X .
X
Bis(2-chloroisopropyl) ether
34283
X
X
Bis(2-ethylhexyl) phthalate
39100
X
X
Butyl benzyl phthalate
34292
X
X
Chrysene
34320
X
X
Di-n-butyl phthalate
39110
X
X
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK141108544006 WastewaterPermitdoc
Revision date: 12/30/97
Page 12 of 20
�`3

s_J
Wastewater Pollutant Checklist
Chemical Name
EPA
Storet
Check if
Present at
Check if
Absent at
Check if
Present in
Check if -
Absent in
Concentration in
Discharge, if
Code
Facility
Facility
Discharge
Discharge
Known .
(mg/1)
Base Neutral Organics
continued)
Di-n-octyl phthalate
34596
X
X
Dibenzo (a,h) anthracene
34556
X
X
Diethyl phthalate
34336
X
X
Dimethyl phthalate :
34341
X
X
Fluoranthene
34376
X
X
Fluorene
34381
X
- X
Hexachlorobenzene
39700
X
X
Hexachlorobutadiene
34391
X
X
Hexachlorocyclopentadiene
.34386.
X
X
Hexachloroethane
34396
X
X
Indeno(1,2,3-cd) pyrene
34403
•
X
X
Isophorone
34408
X
X
N-nitroso-di-n-propylan ine
34428..
X
X
N-nitrosodimethylamine .
34438
X
X
N-nitrosodiphenylamine
34433
X
X.
Naphthalene -
34696
X
X
Nitrobenzene
34447
X
X
Phenanthrene
34461
X
X
Pyrene
34469
X
X
Metals
Aluminum
01104
X
X
Antimony
01097
X
X
Not Known
Arsenic
01002
X
X
0.020 mg/1
Beryllium
01012
X
X
Cadmium
01027
X
X•
Chromium
01034
X
X X.
Not Known
Copper
01042
X `
X
0.11 mg/1
Lead
01051
X
X
0.017 mg/1
Mercury
71900
X
X
0.00040 img/1
Molybdenum
01062
X
X
0.013 mg/1
Nickel
.01067
X
X
0.19 mg/1
Selenium
01147
X
X
0.015 mg/1
Silver
01077
X
X
Thalium
00982
X
X
Zinc
01092
X
X
1.2 mg/1
Title: 11.1 Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97
Page 13 of 20

Wastewater Pollutant Checklist
Chemical Name
EPA
Storet
Check if
Present at
Check if
Absent at
Check if
Present in
Check if
Absent in
Concentration in
Discharge, if
Code .
Facility
Facility
Discharge
Discharge
Known
(mg/1)
Other Inorganics
Barium
01007
X
X
Chloride
00940
X
X
Cyanide
00720
X
X
Fluoride
00951
X
X
Purgeable Volatile Organics
1.1.1-Trichloroethane
34506
X
X
1,12,2-Tetrachloroethane
34516
X
X
1.12-Trichloroethane
wit
X
X
1.1-Dichloroethane -
34496
X
X
1.1-Dichloroethvlene
34501
X
X
1.2-Dichloroethane
34531
X
X
12-Dichlorovronane
34541
X
X
2-Chloroethvl vinyl ether
34576
X
X
-
Acrolein
34210
X
X
Acrvlonitrile
34215
X
X
Benzene
34030
X
X
Bromodichloromethane
32101
X
X
Bromoform
32104
X
X
Bromomethane
34413
X
X
Carbon tetrachloride
32102
X
X
Chlorobenzene
34301
X
X
Chloroethane
34311
X
X
Chloroform
32106
X
X
Chloromethane
34418
X
X-
cis 1.3-Dichloronrooene
34704
X
X
Dibromochloromethane
32105
X
X
.
Ethvlbenzene
34371
X
X
Methylene chloride
34423
X
X
Tetrachloroethvlene
34475
X
X
Toluene
34010
X
X
trans 1.3-Dichloronronene
34699
X
X
trans-1,2-Dichloroethvlene
34546
X
X
Trichloroethvlene
39180
X
X
Trichlorofluoromethane
34488
X
X
Vinyl chloride
39175
X
X
Others
Xylene
X
X
1,2 - Dichloroethane
32103 .
X
X
Styrene
X
X
Title: tU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\1085440Q6 WastewaterPermit.doc
Revision date: 12/30/97
Page 14 of 20

Data Summary Form
<= Receiving POTW
<= Receiving NPDES #
<= Specific Sample Location!
i.e., Give IU Name, IUP#, and/or pipe#
Lab => Laboratory
MDL => Laboratory
Notes =>
performing analysis =>
Method Detection Limits =>
Notes =>
BOD
TSS
Ammonia
<?
Conc. Results from
Lab
mg/1
<?
Conc. Results from
Lab
mg/1
<?
Conc. Results from
Lab
mg/1
Q. = Flow
Sample .
ID, or
Count
Date Sample
Collected
Notes about Sample
M =
E = Estimated
Metered
gal/day
mgd
1
2
3
4
5
6
7
8
9
10
11
12
etc
3/18/2004
120 mg/1
300 mg/1
>0.1 mg/1
3/19/2004
170 mg/1
TNS =>
Max. value =>
Avg. (use 1/2 BDL) =>
Total number of samples =>
Maximum data value (mg/1) =>
Avg. data value, Include BDL values as 1/2 detection limit =>
Citle: IU Wastewater Survey & Permit Application
zi1e name: C:\Docurnents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
tevision date: 12/30/97
Page 15 of 20

Sample
ID or
Count
1
2
3
4
5
6
7
8
9
10
11
12
etc
Data Summary Form
<= Receiving POTW
<= Receiving NPDES #
<= Specific Sample Location!
i.e., Give IU Name, IUP#, and/or pipe #
Arsenic
Copper
Chromium
Cadmium
COD
Lab=>
MDL =>
Notes =>
--------
Conc. Results
from Lab
- - -- --- --- --
Conc. Results
from Lab
----- -- ----- --
Conc. Results
from Lab
-------- --- --- ----
Conc. Results
from Lab
---- ------
Conc. Results
from Lab
Date Sample
Collected .
<?
mg/1
<?
mg/1
<7.
mg/1
<?
mg/1
<7
mg/1
3/18/2004
. .
3/19/2004:
0.020
0.11
-
0
_
TNS =>
Max. Value =>
Avg. (usel/2 BDL) _>
•
Title: IU Wastewater Survey & Permit Application
;Ile name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
tevision date: 12/30/97 Page 16 of 20

Data Summary Form
<= Receiving POTW
<= Receiving NPDES #
<= Specific Sample Location!
i.e., Give IU Name, IUP#, and/or pipe #
Lab =>
MDL =>
Notes =>
Cyanide
Lead
Mercury
Nickel
Silver
Zinc
.
Conc. Results
from Lab
mg/1
Conc. Results
from Lab
mg/1
Conc. Results
from Lab
mg/1
Conc. Results
from Lab
mg/1
Conc. Results
from Lab
mg/1
Conc. Results
from Lab
mg/1
Sample
ID or
Count
Date Sample
Collected
<?Y
?
<?
<?
<?
<?
1
2
3
4
5
6
7
8
9
10
11
12
etc
3/18/2004
3/19/2004
0
0.017
0.00040.
0.19.
0
1.2
.•
.
..
.
TNS =>
Max. Value =>
Avg. (usel/2 BDL) _>
Title: IU Wastewater Survey & Permit Application
File name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Revision date: 12/30/97 . .
Page 17 of 20

Data Summary Form
<= Receiving POTW
<= Receiving NPDES #
<= Specific Sample Location!
i.e., Give IU Name, IUP#, and/or pipe #
Lab =>
MDL =>
Notes =>
Oil & Grease
Cadmium
Molybdenum
Selenium
Phenol
Other
Conc: Results
from Lab
mg/1
Conc.-Results -
from Lab
mg/1
Conc: Result's --
from Lab
mg/1
Conc. Results
from Lab
mg/1
Conc. Results
from Lab
- - Conc.-Results
from Lab
. Sample
ID or
Count
Date Sample
Collected
C7
<?
<?:
<?
<?
mg/1
<?
mg/1
1
2
3
4
5
6
8
9
10
11
12
etc
3/18/2004
3/19/2004
;
0
0
0.013
0.015
0.26
_
TNS =>
Max. Value =>
Avg. (usel/2 BDL) _>
'itle: IU Wastewater Survey & Permit Application
'ile name: C:\Documents and Settings\ak\Local Settings\Temporary Internet Files\OLK14\108544006 WastewaterPermit.doc
Levision date: 12/30/97
Page 18 of 20
Er~~ Lr Li
1 LI r • • .r---

Industrial User Wastewater Survey
& Permit Application
Part V, Waste Reduction Information :
State Pretreatment Rule 15A NCAC 2H.0916 (c)(1)(M) requires Significant Industrial Users to include a
description of current and projected waste; reduction (pollution prevention) activities. The codes listed are
standard EPA codes found. on Toxic Release Inventory and other environmental forms. Please check all
applicable codes for your facility related to wastewater discharge.
Current
Projected Code
Description
W 13 •
.Improved maintenance scheduling recordkeeping, or procedures
W 14-"- -
Changed production schedule to minimize equipment and feedstock changeovers
W 19
Other changes in"operating practices (explain briefly in comments)
W21 -
Instituted procedures to ensure that materials do not stay in inventory beyond shelf-
• life
W22
- Began to test outdated material -continue to use if still effective
W23.
Eliminated shelf -life requirements for stable -materials -
W24 -
• Instituted better. labeling procedures
W25
Instituted clearinghouse to exchange materials that would otherwise be discarded
.
W29 ...
. - • " Other changes" in Inventory control (explain briefly in comments)
W31
Improved storage or stacking procedures
W32
Improved procedures for loading, unloading and transfer operations
W33
Installed overflow alarms or automatic shutoff valves
W34
Installed secondary containment
W35
Installed vapor recovery systems
W36
Implemented inspection or monitoring program of potential spill or leak sources
W39 "
Other spill and leak prevention (explain briefly in comments) -
W41
Increased purity of raw materials
W42 ' •
- Substituted raw materials .
W49
Other raw material modifications (explain briefly in comments)
W51
Instituted recirculation within a process
n

Industrial User Wastewater Survey
{ & Permit Application
Current
Projected
Code
Description
W52
Modified equipment, layout, orfliping
W53
Use of a different process catalyst
W54
Instituted better controls on operating bulk containers to minimize discarding of
empty containers
W55
i
Changed from small volume containers to bulk containers to minimize discarding
of empty containers
W58
.
Other process 'modifications (explain briefly in comments)
W59
Modified stripping / cleaning equipment
W60
Changed to mechanical stripping / cleaning devices (from solvents or other
materials) -
W61
:
Changed to aqueous cleaners ( from solvents or other materials)
W62
:
Reduced the number of solvents used to make waste more amenable to recycling
W63
Modified containment procedures for cleaning units
W64
!
' Improved draining procedures
W65
Redesigned parts racks to reduce dragout
W66
Modified or installed rinse systems
W67
Improved rinse equipment design
W68
.
Improved rinse equipment operation
W71
Other cleaning and degreasing operation(explainbriefly in comments)
W72
Modified spray systems or equipment
W73
j
Substituted coating materials used
W74
Improved application techniques
W75
Changed from spray to other system
W78
;-
Other surface and fmishin
preparation g (explain briefly in comments)
W81
Changed product specifications
W82
Modified design or composition of product
W83
Modified packaging
W89
Other product modifications (explain briefly in comments)
W99
Other (specify in comments )
Comments (Please list corresponding code)
L
L
L
L
L
try

Stearns &.Wheler, PLLC
Environmental Engineers and Scientists.

equencing Batch Reactor systerns-represent a varia-
tion of- the activated sludge process:. Like any other
activated sludge process, the AquaSBR works • by. develop-
ing a mixed culture of bacteria which -is effective in removing
BOD, COD and nutrients commonly found'in wastewaters.
The AquaSBR can -treat. a Wide range of.• domestic and
industrial wastewaters, at flows ranging from a few thousand
gallons to millions of gallons per day.
The AquaSBR is unique in its ability to, act as an equaliza-
tion. basin, aeration basin and clarifier within- a -single reac-
tor..The- termination of flow- and aeration during the treat-
ment process provides perfectly quiescent_ settling condi
tions in -the reactor, and permits -even very fine particles to
settle. -Each reactor.meinteins-its own.treatment regime and
all phases of treatment occur in each reactor.
Optimum performance is attained when two or more reac-
tors are utilized in a predetermined sequence of operation.
Four -basin AquaSBR
in certain instances,. a_ • single reactor may be operated to •
provide an acceptable_ level of treatment: •
Because the: AquaSBR operates.in:a true batch treatment
. mode, optimum- effluent quality is -obtained during** •
cycler Only a•fraction Of .the total reactor .volume; typically.
►/s; is introduced into the reactor•each cycle.=.This raw flow '
combines with the acclimated biomass; which remains in
the reactor at all times.
The ratio of raw flow to biomass is akey factor in obtaining
desired effluent quality results -in the SBR. Since only a
small amount of sludge: is' wasted each cycle, the quality of
the biomass is always. Maintained.
A truebatch reactor system; like the AquaSBR, does not
allow influent wastewater to enter the SBR reactor during
the final aeration, settle and decant phases, thereby assur-
ing an excellent quality of final effluent.
v�:..�•.c:r�d::� i:�-.�>.-.-:: �_!._.�?:��_a.. =-tea;
.i
L:i

• Provides Ideal Settling =':Since there
it; no :flow •to- the- reactor. during' settling; and no •
mechanical Sludge collection- device.:°stirring" ::
the .basin;=ideal quiescent settling conditions
exist:•
Peak Design"Flow.
The AquaSBR:-maintains: predetermined cycle times,: even at
peak daily flow. conditions:_ Cycle integrity is maintained. at: all :-
: • flows up to and equal;to.maximum daily flows. ' •.,
Separation ot Aeration and.Mixing.•
:.
• Aeration =. Can -.be provided;.by._one .of the follow-
• frig .meansEAqua-Jet..surface- aerators; -or -:Aqua*
• • CAM=D.aerator/mixer/decanter;-fine-or:coarse- =_
bubble: diffusers.; (retrievable: or fixed configuration)::.:•
Retrievable; diffuser: systems-. lift from: the. basin -.and
rotate,for-inspection and •.maintenance.. =• .•
• 'Mixing= The separation-,of':aeration Mixing". la ..
- • :.essential to -the. -success of:any .SBR: The•tloating; -
• direct drive AquaDDM mixer.' provides •a 'powerful: •
downflow.discharge for maximum solids -.suspension::
and'aeration: enhancement throughout the besin..-
• Mixing efficiency-is:approximatelythree.to five times•.-:
that - of - jet mixers•or.submerged horizontal -mixers:
The use.-ot: the•:AquaDDM :.mixer.enables'the
AcqueSBR;to..be: operated for: nutrient. removal'and.to
ontrol filamentous:° organisms; by providing amixed;'
non aerated::anoxic'. environment..duringaelected ; .
::: phases of operation. •: `::., -: :: ; ; `
Retrievable and; Accessible: Components The AquaSBR:•
• is::designed to mrnmize.operation and-'mainteriance::All -
.:•AquaSBR_components::are.. accessible from the• side of. the
:: tank;,eliminating: the: need. to`dewater:' ••
.
• Retrievable- Diffusers.
AquaDDM, Mixers
AquaDecanters
.:� Slutlge Pump
s e":Eatch:,Reactor:Systern'.
The.AuaSBR_•:is'o-erated:in.a true batch•:reactor
q p...
� treatment'mode;,which=:does..not�allow•wastewate(,ao- enter
the.reactor during the React;:Settle and. Decant phases: The
system:
•
• .-.Tolerates:-.Variable.: Hydraulic; Loads
liquor: solids_ cannot:: be::washed .Out ;by hydraulic
surges since-_efflue'nt: withdrawal is typically'..
accomplished. in=a.'separate.'phase..following: the
termination' of. flow itoeach.reactor
• ▪ Tolerates: •Variable.Organic Loads Each.influ
ent liquid.batch:is'diluted•with'the reactor, contents .•.'.
from the.: previous. cycle:.': : : ; `'•
Controls. Fllarnentous- Growth ;Filamentous
A
ua-- Aeronlc Manufactured
organisms are controlled by :creating an anoxic
condition during.the Fill phase.-,
mAll•critical: components:of the .AquaSBR are 'designed _and.
anufactured:by:-Aqua:Aerobic ,Systems, .a -reader- in Ina
. AgjuaDecanter. System
This positively sealed:effluent:decanter.system- incorporates::
:: several mechanical: design features and: a," mode;ol• opera :
-Alan 'that :results.in:opiimurii:perlormance:;`This'desi'gn••'=
: assures;that':sub=surface withdrawal,. of supernatant:. will.
-alwaysbe extracted.-from-the°reactor:at:en••adequate-depth
: •and .within, the: diameter: Of 'ihe. flotation. structure to avoid
.:
drawing surface tfieteriatinta the effluent flow.:
Nutrlent.Removal':..
:The ;standerd:AquaSBR. system Can be: operated;lor•nutrient `.:
removal:No :additional -equipment: or::controls area required
no Iicensing.leesare required:in Order to use.the:system•for, -
*'.nitrification; :deniirification.or=ptiosphorus.removal;'if:operat
ed according •to the•instructions'of 'Aqua -Aerobic ,Systems:, •
q.
,wastewater treatment industry for: more • than'25 years:. -The:
AquaSB,Rprovides- you with; one.'company'accountability'for
design;supply; start=up supervision and service
Return •Activated•Slucige Pumping.Eliminated
..Extensive.'piping and.. pumping, for. return activated sludge is
not required since.the: mixed.liquor.remains in the•AquaSB.R ;.•
at'all times:-Sludge.production from: an:AquaSBR Is-compa-
rable•to:a-flow=through--activated' sludge system;::and willayp
icallyproduce:settled-sludge.concentrations of-t%.or:more::,
The system's=.microprocessor can: be programmed:to;waste::;
sludge at the end of every cycle,. during, the.- Decant phase.::
• Lower Inetallailon Cos•ts.•
.:• ::.
.•The: AquaSBR. is.•adaptable.•to_several: basin configurations.-
Nw.eor:retrofit;:lowerinstallation costs are. apparent. with the::.
AquaSBR: This: system,'Serves:as-an aeration- basin;: final.-,-.•
• clarifier: and provides.the. equivalent,ot.flow,equalization It
eliminates the•need•for separate-:structurees. for.. each unit
process: The: use of :.fewer structures in the:_treatment.sys�
tem generally, results in dower: construction and installation •
costs.• :-
• Consistent ,Effluent Quaflty, . _ :::: • : : _- , .: : _
The:use"of. microprocessors: -.allow the operator: to -adjust.:
time and/or aeration and mixing besed.on:organic loads -:and . .
•.-wconditions•to achieve.required.results, :. :•
PLC -Based Control System .
•
The:AquaSBR control system;is:a.•timer.based: system_,with . .
level overrides. This system: provides; control, :sequence •': .
monitoring;;and annunciation capabilities; and is designed to
focus.on an operating'_strategy. to :optirnizeahe biological
• •treatment•process, while minimizing: required operator - alien•
.Control sysiem upgrades to .include a.:P:C. ere.
available: :. .

quaS$R systems are currentlyused in amide variety
of treatment situations; :under a wide range of load=
ing conditions. The AquaSBR processcan be employed to
treat any wastewater. that .can -be treated by activated..,
sludge systems,-including:.-anoxic/oxic systems, aerated
lagoons.or extended aerationsystems;_trickling filters, RBC
systems -and oxidation ditches.
Wastewater treatment applicatiflns include:
1. Domestic applications
• Municipal • Casinos
• Resorts • Institutions
2. Industrial applications
• Chemical/Petrochernical
• Leachate
• Tobacco
• Food
• Pulp and paper
• Dairy
• Beverage
• Textile
• Tannery
• OCPSF.(organic chemicals, plastics,
synthetics and fibers)
• High nitrogen
• Any other wastewater that can be
biologically treated
jY+:
s-_ fit`-`c..•„-`+=.}=��,
Domestic waste treatment with the AquaSBR.
Dairy plant -in--Pennsylvania- effectively treats waste
with AquaSBR:
Covered tank AquaSBR .. =

•
e;use:;ot microprocessor.controlled. phases:enabies.the:operatort'o vary. the. operating strategy of the AquaSBiR.to,suitfreat-.
•`meatrequirementsrlNormally,.the process follows. basic steps-ot FiII; .R:eact .Settle.and•Decant: The ability to: create -aerobic or:
_ anoxic conditions within the reactor!esults:in flexible•operation, better treatment of=yiraste,.and optimum:ettlueni quality:.:: _
`-.Influent' enters: the•AquaSBR reactor Complete mix_ of: the reactor=
-contents is achieved'. without the.use. of aeration: This phase assists -'in: control .=
ot:-'filamentous=organisms,:and:is. essential_ for. those- systems: which. require
• phosphorus removal:; • •
;. d 3-: 5j�• :'Influentflow'continues under mixed and'•aerated conditions
_ '. Aeration. may be; intermittent:.t0 :promote aerobic.•or. ranoxic. conditions.:
Nitrification.• and.;denitrification can. be achieved The:: aeration source. may also:
be operated: interrnittentlyduring low: flow and.low organic •loading condilionsto-•
:conserve energy:
B ac1 'Influent flow is'terrninated, whilernixing .and: aeration .continue:
Intermittent .operation of the'. aeration system may,Continue-,to: complete the
nitrification/denitrification process;'or.to -
cons•erve .energy: •
• �e =Mixing andaeration cease: Solids/Liquid separation takes place: under
perfectlyquiescent conditiions:.'.
l*cadtIISiut e r --.The mixer and. aeration system remain off- and; et- INS--
time;-the'decantable volume •is.removed by- means .01: subsurface .withdrawal
•"The reactor .is -immediately. ready -to -receive the: next•batch, of raw influent: -A-
small amount.' of sludge is=wasted each cycle. - • :
ad3 OCcure in multipte basin systems ariytime that flow conditions. are less
than peak design flow. Idle time variesdepending on actual flow conditions.:. :

L.;..

Clarification'tO below :ap -- 30 PPM • of filterable solidi. Thick
ened sludge consistency is 2 3%;
(tROFTA)
•
. „ •
IANrTAGES
•
tt.1-:•VeriloW retentidri u7: 2.Minutei 30 secOndi.-,.:. .-:•-•,•• •
0*,•::High;,sPeciliOlarificatiOn2OaPacitY.---1. 4--
a smaller itirfaCe aresiv4•., • - •.'- .". -..• . • :
6- ...-Our,chiie • cost .any:OthersYstem of temperable.' -•
. perfOrinance.-.. • .••
6 Installation cOst is the ,imrt is 'delivered fully'
cated; no heavy supports : are needed becauseof, the low
wiught (150 lbs/soft)-. : •
• . - •
The unit niaintains value — reloCatiOn, is easily aeCOmPliihesL.
- , : • . _ • ,
• 0 Space requirements are'ritirtireal, lbw headroom a Equip .
inent, can be erected above ground level
. • • :
. .
:Easy to clean :tank. is completely oPen, bottom Self- '
- • -
_ • • .cleaning • during OperetiOn. ' • :
'33
. .
SORRACELL'is-delivered .fiii1V-.-Prefehricated.. Larger
. - • • • •
unuis
are delivered in parts-,whiCh flange together Constructuon•
• . • materials are Painted 'dr;staunless steel A tile or.concrete tank
is-,.OPtional:'..h1OheaVy:fpupda*p.pr SUpPOrtistruCtureii. needed •
.;"
The c.r..rSUPRACELLws and foreign patents)
is an:adVanced-ClarificatiOn system ; using COM
bined settlingand flotation techniques::
'
The unique compact and efficient design is made ". , • r
• possible by use of the principle of ”ZERO VE-
LOCITY". The (KnoprA)SUPRACELL is smaller
•- • in. surface area for itt, capacity because a:very. -
high SpeeifiC-, clarification: degree is attained
(4 to 6: VSGPM/softL The :Water level in the
• ,
tank is extremely low -i16 This imeans re
duce d -size and• weight linv retention
tine (2niin.'30 sec.). : ; • :
' • ' " . • - . • - ,
The (KROFTA)SOPRACP..L'is espec,ally advanta;
eous :for. Situations • in -which ,thel sludge , or
•• water is recycled to the process -end:Where:the
• type of Awaste water Varies: The Syria!! -volume:: .."
and short.- retention ..• times are important for
Closed systeri, �petation Units re in.OPeration-,: - ' . • •
!I-pi:lip; and,- paper; Deinrcing. Food Processing :
_ _
Latindry. EiolOgieal Sludge Thiolcening and MU--•
: , : • : ".- icipal Effluent.dlarificatiOn, Installation is:Pei.
ihle above.flab,- :lei,e1; OVer Martini chests Or .•
-..
as the total load factor when filled with Water:weightileis than • meehinery. rOoftOps. or stacked one over anoth
.. L.---,
er in multiple unit use. , .
' .
- ' " • .
• •
- . . •
. . - . . • • . . -• •
. , • , • . • - - - • . - . • = • • • . • • . - • .
. - • . . , •

STALLA TI
ig. 3rf:15 SCJR IRT.ION_
1:;ROTATI,NG, CENTER.
2: CLARIFIED: WATER,OUTL'ET
3;SETTLED: SLUDGE. 'SUMP. •
. '.4' SETTLED'SLUDG,E.;OUTLET;._
5' 7• .ROTARY:CONTACT. ;.s:.
'.6: SPIRAL SCOOP "•
7- FLOATED`S'LUDGE OUTLET-
8; UNCLARIFIED.. WATER INLET":.
• 9- CLARIFIED- WATER-EXTRACT•ION:.' PIPES::: .
10:GEAR.'MOTOR. :,
11 .DISTRIBUT.ION._DUCT•
�PERATPON;AL DES,CRIPTIO,N;
- The inlet outlet and".sludge removal" mechanisms.ere'.cori•
.tined" in the. central':rotating;section.-This section .arid .the'.
Spire] Scoop rotate around ;the::.tank:.at.a':speed synchro•.
niied With the limn,:
Unclarified Water, :first_.passing.throtigh. the(KROFTA)AIR'DIS.
SOLVING TUBE "(see, page6): s..released through' a rotary
joint.inthe center;•of.the:tank,': It. then. passes: into' the-dis '
:. tribution `duct . that moves :forward.•with, the same"Velocity
as .the _incoming. water, thus: creating : 'ZERO:.VELOCITr%
The: settling. and the.':flotation:processes'take'.place in this •
.quiescent state.
•
•
The patented SPIRAL SCOOP takes up the floated
sludge; pouringit. into'the•stationary center section where it :.
is dischargedby gravity foreither recycling or disposal
Clarified water is removed: by. extraction pipes which ere :at:.,
tached:.10 the moving, center; section;. The clarified -water
which .normally. Contains :less'then '30PPM_'of: suspended
solids can be recycled in theprocess and/or severed.'.'
-.Wiper blades attached 10 the ;moving;'distribution:.duct
scrape; _the. bottom; and -the :sides'.of:the tank- and_ discharge_ -
•. settled sludge: into. the. huilt•in'sump; for periodic purging: •
;The -;variable _speed ,gear-rnotor: drives :the; rotating elements
:and scoop:: Electrical-currentfor-the gear moto•r feeds from'
:. a -rotary contact mounted on;the central.shaft..
0 0
7fim!og%il_ m I
,\N,........_
11)
:Fig .3
-A. DIAMETER-of_SUPRACELL
•B D'EP.TH of SUPR'ACE LLTANK
C DEPTH of SUPRACELL TANK with.BOTTOM SUPPORT,.
D MINIMUMO.V.ERAIL ,HEIGHTo1SUPRACELL.'.,.. .
TYPE :..
.... DIMENSIONS"..:,'
:,.:. .
:F•LOW.
:fi-
.mm-'•,
iri ,'
Trim':
in`. ;mm-
.In.
mm.-
n/min
GPM.,.•.Ri3/A
84
`•
2409
;235;
. Sob '
.33
.860 •
46!
175o
:.Qes
7e}&'.
1 D`
' ..320o
?23.5,
•600
L33:
, 850
`=49
,1250.
• '7,00,
a 263E
'- ,'60
t,-
,3900
2&5
-650
9b:
' sea
51
,1300
.'I so.:
394''
_ 90'.
?::ik
'. ,4500
25.6
':660.
5374
.950
'Ir57"s
,1450
2.00
- 525'/
' ':.120 -:
-78
:•'`.. 5500
,.25.5
,=650•
37
•950
'S8
-1480
"-.3,00,
: 7t399
--`;180•. •
• ;1'20•
' .6100
25 5,
: 650'•
.37
. 950..
61'
-1560.
-...3,65 ;
.. 961.:.
-::219- •
!22'
.. 6700
25:5;
; 650
37x
950-
`:62•
1680
-- • 4;40
"-11604
'; '264 -
: :305!
2ai
,. 7200.
525.5;
650
;37'
.950:
'.63';
: 7600.
•-5.08;•
•,1340 %
i 27
j.8700.
° 25.5!
',650-
.4 c
,'950'-'r67`-
,1700 _
6.44
Y.ieSs }
, '388- .
130i
• -, 9000:
, 26.5
650:
'`+37
1950
' 71
1820 :
' 7.95a
„2040
" ,'_`477,
{33=
10000
25.5i
:650:
-; 3Z'
; 950.
72;
' 1840"
_ 9.80:•
: 25801
. 588
36
,11000
:-25.51,
650
37
.950
,' 73
-•1860
-11.874
=312t§'.
',,712 _-.
`.A0;
. 12200-
26 -,.,•;
:680
38'
'.960,.
76_'
:1920.,
14.0.
38401
'.::876• . -I:
fi44?'13400
'27
-685
39
:985-;,72
=198D-
.17:60.
•4630;
1056 --
48
-14800,
:27 -
685:
_99
985'
62,
2070:
21;50-
5650°
:1290 `
65'
16800
,.27:.'
685'
"39-'985'
87!
`:2200.'
.27.70.:,
"7290
.'1662-
;62
:78900
; 29.5,+
,750
i`4
:1050
`93
:2350_
'33.30•
,,8800i
"..,2000•
's70:
21300
29:5'
;750
47?a
.1050
: 93
i ,2350.
, 41.60
-'170o0I
.."2500.
ge.3:

.DESCRIPTION,"
1 RAWWATER COLLECTION TANK
"
2 SUPRACELL PEED PUMP
•
3 SUPRACELL INLET PIPE-'• • .
. • -.. . •
• .*•liribecdel0 In ground) . •
4 INLET COMPARTMENT.--•
• 5 ' SETTL5DSLLIDGESUMP.-- ..•
. . . •
DISCHARGE:7 CLARIFIED WA1ER OUTLET
• •
•
- •8 CLARIFIED WA7ER RETUPN or- 7
LEVEL OL•(1). '- • •
• • - ..•.•
•
9 LEVEL .CONTR01,:in SUP RACE 4.
• _•„.• .
-••• • •-• With -PNEUMATIC.SENSOR and ••'-"
cL?Fki7OF.40..ivoai,np1SCHAROE:
, .REGULATNG VALVE..„..
..•' • • .• ity• RECVCLING
PRESSURE PUMP for
•-•of CLARIFIED WATER2o !the A1151'--•••
. .. •
oissotwiNo-r.upEs.. •:. .
. .
; • • -11 1.•••
MRC
. . .
12 :SUPFIAcELL MAIN TANK • ..
• 13 SPIRAL SCOOP lor . ' ' • -
r.'• • nl•Ine FLOATEDSLUDGE_ •
,FLOATe1) l‘UapE - ..• ••
15 3TEEC•L5aS -
- .• . " • •
: • ' •16 SECOND ELEVATED suPnAciLL
- in STE5L.CCiNSTRUCTION .• • •
. .
. '
•
. .
• • •
. .
•
' • . .• . • •
DESCRIPTIO
• -
• . , • . •
LLATLONS
•
- : Fig 4:
Two SUPRACELLS 5511 diameter
-.Flo*, 10.5 US:MGD each:'Total flow 21 0 US MGO sr
For large: '!low (5. us:.mg
, . SUPRACELL.Tfied.•ivater discharge vaive Alternately an snbuilt central
tnstallatson thetotal cost can be '..kent Iow by installing -: • :-.clarifued.• water Oi!erfloii is regulated 1 rom the rotating f
the SUPRACELL on a.'flafecincrete ground pad. Because • .. manual or remote controlr •
of .the)OW: Water -lave!'in die•:tankAncirmal heught 16 For doublung the CaPaClty .a SeCand.-SUPRACELl._ can:be
emergency overflow :241 the niaXimtirriload'.0ii the --• • 'inttailed on 4, legialier.the- bottom 'On“see. ft; 41-•This
• • .•., cohcre4:,plosidso Iblisqft.:'(Leis-than for a Oarkinifot.) • • • ...:•secOnd-SpiiRACELL 15 livilt'jn. steel 'With:steer lutlriottO.:. •
'" • • • • • • ' • Because of,. the :IOW•faad when filled, .sOCh.COnStruCtiOn•is
• • • . • • • . .
- : The' raiw.-ater- inlet, clarified Water. outlet and-d-thidge reCommeaded.WhereSnace 'it atpreiniurn..: . :
4isiherge, .pipes are inbedded in the groisnd under the
concrete Pad. :The Water level in the SUPRAC4LL is Con;
trolled, by a pneumatic senior, Which regulates the clarir
• • . . • • - • • . • • . ..• • ,
. . • • " • • ; •
. ..•
. • . .
. . .
• •
- • • - • • . ' - • ' • • . . • , • • .
. •
• - • • . .
. • - • . • ... . • • •
Installations Of 3 SUPRACELLS snstalledone over the
. - Otherhave been bUili, all incorporated in lightWeigb! :_ •
hauling. • . " :
• • • ....• • •• • • -„ • •
. ; • • • .. • • •, • . •
Page.4 •
• .. •
•••
- •

1
•
—,
FOCUS ON: SLUDGE MANAGEMENT
rading a traditional
activated sludge process
By Richard C. Hayes, director of marketing, Krofta Engineering Corp., Lenox, Mass.
Wastewater flows are increasing at many :municipal -
and industrial water and wastewater treatment plants;
placing some facilities in a -hydraulic or biologic over•-.
load condition. The consequences. are-poor•quality .
effluent and, in some cases, borderline- permit - --
compliance. .
The proper solution may be -difficult to find: Addi-
tion of more aeration basins can provide longer reten-
tion times, but at a prohibitive cost. However, a
permanent and economical remedy may be found in .
activated sludge processes: in particular, advanced
"flotation technology involving the use of a dissolved -
air flotation intermediate clarifier after the aeration
basin and before the final clarifier. - .
Incorporation of advanced flotation technology
Into. the treatment train. enables -aerobic biological
organisms to be recycled to the aeration basin and
Tess flow to be sent to the final settling units.
Benefits include additional retention -time in the •
aeration basin, reduced solids loading on the secon-
dary clarifier, and an increase in the plant's ability to
handle shock loads.
Perhaps the greatest obstacle to application of
advanced flotation technology to more varied
wastewater treatment challenges is simply traditional
thinking. The technology has been well accepted fors.
conventional thickening. However, thanks to anew, '
dissolved•air flotation unit called . the Supracell,
advanced flotation technology can also be used to
float solids that have a tendency to settle, or to be
dispersed in suspension, and it can be applied in
altogether different stages of the treatment sequence. -
• . •, A conventional sedimentation clarifier has an oper•.'
ating water level of 1210-16 ft: that of a conventional
ttotatitirt•Ctafffier; 6 to 16 ft. By contrast. the Supracell,
a high -rate flotation unit manufactured by Krona' Engi-
neering Corp., has an operating level of -16 to 18
• inches. Its design principle is that the Inlet and outlet
.li!r,eJotating about the center (see box at right of p.
:21-f'Thls allows better clarification in smaller surface
•
areas and in a much shallower tank. The shallow de-
sign"also permits easy installeticie and high capacity
while ensuring the necessary effluent- quality.- Since
the retention time in the.Supracell'is less -than 3
minutes, the unit is much smaller.than-a conventional
clarifier -which means lower initial and • installation
costs=but it can -handle an-equivelent-flow:
The.Suprecell distributes -the inlet flow over the
entire surface'of the clarifier: The extraction of water
through a water outlet is also performed across the
clarifier's entire surface. These distribution techniques
resolve,hydraulic imbalance difficulties that frequent-
. ly afflict many clarifiers and limit their capacity. Zero
velocity, or quieting of the water, also makes the unit
. more efficient than conventional flotation cells. A spiral
(instead of apfough-type) scoop leaves the sludge
intact and removes- it at a higher consistency.
Air injected at 90 psi into the air -dissolving tube
•;is distributed through porous plastic panels on both
- sides of the tube to create very fine bubbles. When
the bubbles are released into the clarifier, they make
lifting of all the particles easy.
This article describes how the Supracell was used
to upgrade a traditional activated sludge plant of a
Texas paper mill.
PROCESS UPGRADE
When the Newsprint Div. of Champion International
Corp., Lufkin, Tex., began experiencing rising sludge
problems in its wastewater treatment systemand a
drop in effluent quality, the paper mill conducted a pilot
study of flotation. It compared the results o1 a pilot
plant utilizing a Supracell clarifier to those using a
conventional flotation clarifier. The trial results
suggested that the Supracell would offer a new level
of efficiency in the state-of-the-art of clarification:
• The effluent from the aeration basin was found to
thicken readily to about a 2 percent consistency in
the' Supracell. -
• Microscopic examination of suspended solids in the
:. The Krolfa 5S•R Supracell advanced notation clarifier handles 8 mgd from the astragal basin.
Reprieted'and copyrighted u pan of.
-"WATERWORLD•NEWS
Vol. 3, No. S: September./October 1917 •
thickened sludge showed the microorganisms to be
more active than those in the existing recycled sludge ;
system because of the higher dissolved oxygen con;
- tent in the sludge as a result -of the short retention' in
the Supracell. " =
•
• The Supraceti's- removal efficiency of- 80 to 90 -
percent substantially reduced the solids loading to the .
final clarifiers. - .
• The capacity and efficiency of the Supracell were
- superior to that of the conventional unit.
A Supracell unit was installed in the summer of
1983 to help upgrade the existing biological treatment
system for the 1000 ton per day newsprint mill. The
wastewater treatment plant at the paper mill treats
about 18 mgd inlet and has been in operation, since
1967. It was designed for an efficiency of 20, ppm,
of biological oxygen demand (B00) effluent and 20
ppm of total suspended solids (TSS) effluent. Sever-
al expansions .resulted in borderline permit compli-
ance, particularly in the winter when the BOD'Ioading
was higher.
The plant's primary objective was to achieve
compliance with EPA standards for BOD effluent by
-reducing the amount of solids going to the clarifiers.
This, in turn; would reduce the level of solids in the
effluent. The options included increasing the aeration
- basin -retention time from two to lour hours by adding
another aeration basin of the same size. Although this
would probably have been the first choice, says Mark
Childers, manager of technical services at Champion,
the mill did not have enough land space and the capital
. expenditure for such equipment would have been pro-
hibitive.- Instead, it was decided to improve.the effi•
ciency.of the existing treatment plant by installing, at
one -eighth the cost, a 55•ft•diameter Supracell, which
would handle about 8 mgd of the plant's flow. The unit
18 MGD
(SCREEN
9 MOD • • 1 9 MGD
AERATION BASIN
7 .B,HOUR
RETENTION TIME
•
10 MGO
SLUDGE RETURN
AT 0.4 PERCENT
TREATMENT PLANT
EFFLUENT TO OUTFALL
Process flow before installation of the Supracell •

A closer look at the Supracell
4, 18 MGO
SCREEN
9 MGD j 9 MGD
PRIMARY
SETTLING
CLARIFIER
0.5 MGD
SLUDGE
RETURN
AT 2 PERCENT
AERATION BASIN
2•HOUR
RETENTION TIME
WEIR
7.5 MGO
KROFTA SUPRACELL
FINAL
205•FT
SETTUNG
CLARIFIER
25 MGO
3.5 MGD
3.5 MGD
PRIMARY
SETTLING
CLARIFIER
)I MGD
SLUDGE RETURN
AT 0.4 PERCENT
(ORIGINALLY
10 MG0)
0.4 0.4
PERCENT PERCENT
118 MGD
TREATMENT PLANT
EFFLUENT TO OUTFAU.
FINAL
205•FT
SETTUNG
LARIFIER
Process /low alter installation of the SucroseM
would be used as an intermediate flotation clarifier
alter the 2.5-mil-gal aeration basin and in front of two
205•ft•diameter final sedimentation basins.
Since the inclusion of the Supracell in the plant's
activated sludge process, excursions above the
permitted 80D levels have been eliminated.
FLOTATION TREATMENT TRAIN
At Champion, an 18-mgd inlet passes through a
preliminary screen and splits into two equal portions
before passing through two primary settling clarifiers.
The two (lows converge and are joined by 7-mgd
sludge return from the final settling clarifiers and 0.5
sludge return from the Supracell. This 25.5•mgd flow
enters the aeration basin where active microorganisms
consume waste in a biological process that takes
place over a two-hour retention period. From the outlet
of the aeration basin. 8 mgd are diverted to the
Supracell and the remaining 17.5 mgd head toward
the secondary clarifiers, joining up with 7.5 mgd
hydraulic flow from the Supracell. This is the amount
that remains after 0.5 mgd has been removed and
returned to the front of the aeration basin in a sludge
return of 2 percent consistency.
The sludge return to the aeration basin from the
Supracell at a flow rate of 0.5 mgd is five times thick-
er than the 0.4 percent consistency sludge return
from the secondary clarifiers. As a result of increased
sludge consistency in the Supracell, the hydraulic flow
to the aeration basin and final clarifiers is reduced.
resulting in increased capacity. Since the total amount
of sludge is reduced by 2.5 mgd (3 mgd is saved from
the secondary clarifiers but 0.5 mgd from the
Supracell is added back), or 1 700 gpm• the retention
time in the aeration basin is increased 10 percent. to
2 hours. up from 1.8 hours prior to the Supracell's
installation. (At that time. a flow of 28 mgd passed into
the secondary clarifiers and 10 mgd retum sludge
went back to the aeration basin.)
The 7.5-mgd Supracell effluent contains about 50
to 100 ppm suspended solids without the addition of
chemicals. This clarified water dilutes the 17.5 mgd
coming from the aeration basin. totaling 25 mgd. and
proceeds to the final clanfiers. At this point. the solids
loading going to the final clarifiers is reduced by more
than one third. by about 64 tons a day down from
a total of 180 tons a day prior to the installation of the
Supracell.
The 7-mgd return sludge at 0.4 percent consist-
ency is channeled back to the aeration basin. and 18
mgd leaves as treatment plant effluent to outfall.
The Supracell clarifier. which handles about one
third of the actual pow from the aeration basin to the
final clarifiers. functions as follows: About 8 mgd of
In the Suprace8. the inlet and outlet are rotating
about the center. This allows better clarification in
similar surface areas and in a much shallower tank.
Inlet flow. At the pressure release valve, absorbed
air is released into the water. The water lbws in at
the exact center, through a rotary joint and into the
ROTARY
JOINT
PRESSURE
RELEASE
, VALVE
l
DISTRIBUTION
DUCT
distribution duct.
Clara led wafer pullet The clarified water. near the
bottom. is removed by slotted outlet pipes. The
pipes are attached to the well of the moving center
part. The clean water flows into the center section
and overflows over Inc central telescopic weir.
AUTOMATIC w
REMOVAL OF
SETTLED MATERIAL
CENTER
SECTION
REMOVAL OF FLOATED MATERIAL WITH SPIRAL SCO0P
SCOOP OVER THE FLOATED SLUDGE
SIDE VIEW OF SCOOP OPERATION
CENTRAL
TELESCOPIC
WEIR
mixed liquor suspended solids are pumped to the
Supracell clarifier. A clarified -water sidestream of
about 1200 gpm is pressurized to 80 psi: air at 90
psi is injected into the air -dissolving tube, which con-
tains the pressurized water. This mixture is added to
the feedline of the unit. where the air bubbles are
released.
The water in the clarifier is quieted by a moving
fence in the circular, 18-inch-deep clarifier. The solids
quickly float to the surface. The short. 3-minute-
retention time in the Supracell means that a complete
recycling from the aeration basin to the Supracell and
back to the aeration basin takes less than 15 minutes.
The Supracell uses the rotating spiral scoop to collect
the sludge, which totals 45 tons a day. from the
surface.
A reduction by at least 30 percent of solids going
to the final clarifiers was sufficient, engineers at Cham-
pion calculated, to bring the final 800 and-TSS effluent
from the secondary clarifiers within the permitted
range. Because the installation of the 55.11 Supracell
was intended to handle only a partial flow. the effi-
ciency of the operation was somewhat indeterminate
prior to actual startup, and contingency plans were
made. The installation was designed so that a second
55•ft•diameter Supracell unit could be directly mount•
ed above the original unit. (The Supracell's founda-
tion loading of 150 Ib/sq It or less makes possible
double or triple stacking of the cells.) However,
because the wastewater plant has operated success-
fully 'since the installation of the unit. it has not been
necessary to add a second intermediate clarifier.
The Supracell's solids removal efficiency consis-
tently has reached 80 to 90 percent. The ultimate
reduction of the solids loading to the final clarifiers by
about one third is substantial. Had the Supracell been
designed for a full -flow position in this application, the
actual increase in design flow could have been as
much as 40 percent. compared to the approximately
10 percent increase achieved on the partial flow
basis.
OPERATIONAL EFFICIENCY
When Champion selected the Krofta clarifier• it was
influenced by the superior scoop design. liquor distri-
bution device, equipment construction. and its ability
to operate with little attention and maintenance.
Childers says. The treatment plant's expectations
were borne out during the test winter of 1983.1984.
when several distinct improvements were realized:
• Increased sludge viability —The floating of the sludge
with the Supracell's short retention time meant that live
microorganisms were returned to the aeration basin.
helping to keep the aeration process active and stable.
The plant was also able to recover quickly from heavy
waste -load liquor spills. The regeneration of microor-
ganisms in two to three days. compared to the 30-day
period required prior to the installation of the Supracell.
meant that plant stability and consistency were also
increased.
Studies in other applications showing a higher
dissolved oxygen content in Supracell effluent than
the dissolved oxygen content in sedimentation clari-
fier effluent also indicate that the quality of floated
sludges is better than that of settled sludges. Com-
parisons show the Supracell sludge to of ter a higher
dissolved oxygen content. higher total. solids con-
sistency. and more solids volume in a mucn lower
sludge volume index.
- .• Increased aeration basin retention time —A .10
percent increase from 1.8 to 2 hours in the aeration
basin enabled the biological process sufficient time
to be effectively completed.tt was made possibte:by
the reduction of 1700,gpm in the Supracell return
'sludge flow. . .
• Reduced solids loading to the final clanfiers—The
reduction of solids and the reduction of hydraulic flow
(to 25.5 mgd. down from 28 mgd).to the secondary.
clarifiers enabled them to perform above permit
requirements.
The solids -reduction efficiency achieved by a con-
ventional flotation clarifier at one -fifth the size of a
sedimentation tank alone warrants expansion of the
use of flotation for clarification purposes. However.
in this case. where the Supracell functioned in the
Champion wastewater treatment system. the clarifier
function was only one feature. As indicated. there are
many more to be found by simple investigation.

F.O.:Box 62 .
�lvrtla..E.Bke, Wisconsin 53064

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Steams:: &Wheler, PLLC . • .
Environmental Engineers and "Scientist's:

UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
CUMBERLAND AND HOKE COUNTIES, N
SOIL LEGEND
The tint letter, always a capital, is the initial letter of the soil name.
The second letter is a capital it the mopping unit is broadly defined
]J; otherwise, it Is a small letter. The third letter. it used. is always
o capital and shows the slope. Symbols without slope letters are
those of nearly level soils or miscellaneous areas.
•
J The composition of these uniu is more variable then that of
others In the survey area but has been controlled well enough to BOUNDARIES
be interpreted for the expected use.ol the soils.
National, state
SYMBOL NAME
CULTUI
County or par.
ABA Altavista fine sandy loam, 0 to 3 percent slopes
AuA Auiryville loamy sand. 0 to 2 percent slopes Minor civil div
AyB Aycock loam. 1 to 4 percent slopes
Be8 Blaney loamy sand, 2 to 8 percent slopes Reservation (n
BaD Blaney loamy sand, 8 to 15 percent slopes state forest
and large ai
BdB BleneyUrban lend complex, 2 to 8 percent elopes
Bd0 BieneyUrban Tend complex. 8 to 15 percent slopes
Br8 Bragg sandy loam, 1 to 4 percent slopes
BuA Butters loamy sand. 0 to 2 percent slopes
By Byers loam
CBB Candor sand, 1 to 8 percent slopes
CaD Candor send, 8 to 15 percent slopes
Cf Cape Fear loam
Ch Chewacla loam
Co Coxville loam
CrB Craven loam, 1 to 4 percent slopes
CT Croatan muck
De Deloss loam
DgA Dogue line sandy loam, 0 to 2 percent slopes
DhA Dothan loamy send, 0 to 2 percent slopes
Dn Dunbar loam
DpA Duplin sandy loam, 0 to 3 percent slopes
DT Dystrochrepts, steep
ExA Exum loam, 0 to 2 percent slopes
FeA Facevllle loamy send, 0 to 2 percent slopes
FeB Faceville loamy sand, 2 to 6 percent slopes
FeB Feceville•Urban lend complex, 0 to 6 percent slopes
Fu8 Fuquey send. 0 to 4 percent slopes
GdB Gilead loamy send, 2 to 8 percent slopes
GdD Gilead loamy send. 8 to 15 percent slopes
GoA Goldsboro loamy send, 0 to 2 percent slopes
Gr Grantham loam
JT Johnston loam
KaA Kelmie loamy sand, 0 to 2 percent slopes
KeA Kenensville loamy send. 0 to 3 percent slopes
KuB Kureb sand, 1 to 8 percent elopes
LeB Lakeland send; 1 to 8 percent slopes
Lb8 Lekelend•Urban lend complex 1 to 8 percent slopes
Ld Lenoir loam
Le Leon wnd
Ly Lynchburg sandy loam
Mc McColl loam
Na Nahunte loam .
NoA Norlolk loamy send, 0 to 2 percent slopes
NoB . Norfolk loamy send; 2 to 6 percent elopes
Pa ' Pactolus loamy sand
Pp Pentego loam
Pt Pits•Terboro complex
Re Reins sandy loam
Ro Roanoke and Wahee toems
Flu Roanoke -Urban land complex
St Stallings loamy sand
TaB Tarboro IoemV sand, 0 to 6 percent slopes
TR Torhunts and Lynn Haven soils
Ud Udorthents, loamy
Ur Urban land
VeB Vsueluse loamy sand. 2 to 8 percent slopes
VaD Vsueluse loamy sand, 8 to 15 percent elopes
VgE Vaucluse•Gileed loamy sands, 15 to 25 percent slopes
Wee . Wegrarn loamy sand. 0 to 6 percent slopes
WgB Wegrem•Urban lendcomplex. 0 to 8 percent slopes
WmB Wickham line sandy poem, 1 to 6 percent
Percent slopes
elopes
WnB Wickham•Urben land complex, o
Wo Woddington loamy sand
Land grant
Limit o1 soil st
Field sheet ma
AD HOC BOUNC
Small airport,
cemetery, c
STATE COORDI
LAND DIVISIOT'
(sections and I
ROADS
Divided (medi.
if scale per:
Other roads
Trail
ROAD EMBLEM
Interstate
Federal
State
County. farm
RAILROAD
POWER TRAN!
(normally no
PIPE LINE
(normally no
FENCE
(normally nc
LEVEES
Without root
With road
With radroai
DAMS
Large' (to st
Medium of
PITS
Gravel pit
Mine or qu

Stearns -&:Wheler, PLLC_
LEnvironmental Engineers and Scientists

Opinion of Probable Project -Cost. .
DAK Resins -Fayetteville,-North Carolina
S&W Job No. 40159.10
Alternative No. 2 - Upgrade Cedar Creek. WWTP and Maintain NPDES Permit
and :
Alternative No. 4 = Upgrade, Cedar Creek: WWTP and Dis•charge ,to Fayetteville PWC System .
4 Construction•Costs , _ ., .
Item •
. _Description:- :
Quantity
'Units
.Unit?Cost
"Markup
•'Installation :
:, "Cost`..:
1
Mobilization/demobilization
1
LS
$ 30,000.
0%
$ : -
0% ,
$
$ 36,000
2
Dissolved Air Floatation
1
EA
$ -130,000
20%
$-26,000
50%
$ 65;000:.$
221,000'
3
Floating Aerators
4
EA
$ 35,000.
20%
$ : 2000
20%
$ 28,000 -
$ 196,000
4
Blowers
2
EA
$ 15,000
20%
$ - 6,000
:50%
$ 15,000
$ 51,000
5
DAF Feed Pumps
2
EA
$ 8;000,
20%
S.- 3,200
50%
$ 8,000
$ 27,200
6
Pump Control Panel
I
LS
$ .: 12;000.
20%
$ 2,400
50%
$ • 6,000 -
$ 20,400
7
Piping and Valves
1
LS
$ - 30,000.
20%
$ 6,000
50%
$ 15,000.
$ 51,000
8
Concrete
90
CY
$ - 400
.0.%
$ -
, 0%
$ - .
$ • 36,000-
9
Erosion and Sedimentation Control -
1
LS
$ 5,000
0%
$
0%
$ -
$ 5,000•
10
Electrical
1
LS
$ : 70;000
•0%
$ -
0%
$ -
$ 70,000.
subtotal .
• . .
:. 710,000.
-. Contingency- .. ;-•..20% '..: .... - $ . .150,000.
Opinion of Probable Construction' Cost $ 860,000
" Related,Costs-: _
_ .,, Description - " - -"
Quantity
_Units
;'Unit Cost
= " -
Cost.,
Basic Engineering
1
LS
$ 86,000
$ 86,000"
Contract Administration (2°/u-of'construction) ' -
1
LS
$ - 17,200
. -
$ - 17,200
' Opinion of Total Related Costs $ - 100,000
- Opinion'of Probable Project•Cost---. $. 960,000:
Stearns & Wheler;-PLLC
•

le , ;e at to
,lltenance Cost
Stearns. & Wheler, PLLC;
Environmental Engineers and Scientists .

Opinion'of Probable Operations and Maintenance Cost
DAK Resins - Fayetteville, North Carolina
S&W Job. No; 40159.10
Alternative Na. 1=-No. Upgrades. and: Maintain NPDESPermit.::
,,Item
,.;' -..Description- . ..... ' .:- - _ •, _
Quantity I _ Units, I: ;UnitCost.I .; _. _:Cost'.:..
1
Electricity
700
kWh
$ 0.045
$ 276,000
2
Nutrients
1
LS
$ 30;000
$
30,000.
3
Chemicals
1
LS
$ 195,896
$
195,896
4
Lab Expense.
1
LS
$ 156,000
$ 150,000
5
Sludge disposal • •
1,425
lb
$0.25 •
$
130,000
6
Maintenance and materials
1
LS
$ 100;000
$
100,000.
7
Administrative
1
LS
$ 120,000
$
120,000
Opinion'of Probable Operations. and Maintenance' Cost
,$;•
1;007,896._
Notes: - -
1. Costs for electricity, chemicals, solids disposal, labor and maintenance provided by-DAK Americas based on previous year's.data.
Stearns_&-Wheler, ALLC-
�,-Ernirorimental Engineers, and Scientists -

Opinion Of PrObable OpeintiOns and Maintenanee Cost
DAK Resins - Fayetteville, North Carolina
S&W JobNo. 40159.10
Alternatives NO: 2 4 . Up:grade:Cedar Creek WWTP..and Maintain NPDES Pekin -it,
.
:
‘
., . , ., , , t •. . . ,
. ,..
:
, Item 1- -. --...- :, , ':':-....::--:-Description -,, - , - 1 : ' , I Quantity [ Units •I UnitCosel. ..-',- :Cost ,I
1
Electricity
150
kWh
$ 0.045
$ .00,000
2
Chemicals
1
LS
$ 100;000
$ 160;000
3
Solids disposal
1,250
lb
$ 0.25
$ 115,099
4
Nutrients
1
LS
$ 30,000
--$- 30,000
5
Maintenance and Materials
.1
LS
$ 50,00.0
$ 50,000
6
Lab Expense
1
LS
$ 156,000
$. 156,000
7
Administrative
1
LS
$ 120;000
$ 120,000
()Pinion of Probable Operations and Maintenance-COSI! ,$._ ' 640;000
- . .
• - Stearns8' -Wheleri PLIC
-• -Enviroqmqntal driirieers and Scientis!s

•.Opinion' of Pirobable Ope>tations and Maintenance: Cost
DAK Resins -"Fayetteville, North Carolina
S&W Job No. 40159.10
Alternative. No. 3- Discharge Untreated Wastewater..to. Fayetteville.PWC's System .`
'Item - ,�.... .,Deseription . ; - . , , 1 Quantity I ,Units•'I':Unit.Cost I
_ • Cost
1 POTW Cost for treatment - flow. based - normally 100% of time 400 . 1,000 gpd $ - 3.29 . $ 481;000'
2 POTW Cost for treatment = BOD'based= normally 80% of time 3.;980 . lbs/day $ " 0.31.15 $ 363;000.
_-
3 POTW Cost for treatment=.BOD based_ .= peak discharge 20% of time 10,200 . Ibs/day $ - 0.3115 . $ 232;000
4 POTW Cost for treatment -.TSS :based = none normally 0 lbs/day . $ 0.1342 $
5 POTW Cost for treatment "- TSS based - peak discharge 20% of time 2,500 lbs/day - - $- 0.1342 .$ 25,000-
6 Electricity 0 kWh - $ 0.045 $
7 Labor 0 LS - $ - $ •
8 Maintenance 0 LS $ - $• -.
9 Lab Expense 1 LS $ •156,000 $ _ 156,000
10 Administrative 1 LS $ 120,000 $ 120,000
Opinion ofProbable Operations. and Mainteriance-Cost
$ - .1,380,000.
L�Stearns. & Wheler, PLLC
, Environmental Engineers and Scientists

Opinion of Probable Operations :and :Maintenance: Cost
OAK .Re sins - Fayetteville, North Carolina
S&W Job No. 40159:10
: Alternative No. 4 -. Upgrade- Cedar Creek WWTP and,Dischargeto'F. ayetteville:PWC-System .: - -
Item ' :I -_ . _ . Description, .... ; • . I Quantity I Units .I, Unit. Cost .
I. • . Cost
1 POTW Cost for -treatment - flow based -, normally 100% of time_ 400 1,000 gpd $ 3.29 $ 480,340.00.
2 POTW Cost for treatment = BOD based - 0 ; lbs/day $ . 0:3115 $
3 POTW Cost for treatment - TSS based . 0 Ibs/day $ 0.1342 $ -
4 Electricity 250. kWh. $ 0.045 $.-.: 99,000
5 Chemicals 1 LS $ 100,000 $ - 100,000.
6 Solids disposal 1,250 . lbs/d- $ 0.25 •$ 115,000-
7 Lab expense .1 LS _ $ 156,000 $ 156,000
8 Maintenance and materials I- •LS $ 75,000 $ 75,000
9 Nutrients 1LS $ 30,000
10 Administrative 1 - LS $ 100,000 -$ 100,000
Opinion of Probable_ Operations and Maintenance Cost
$"• 1,160,000
Stearns 8& Wheler, PLLC
Environmental Engineers and Scientists

. .
. .
Opinion of Probable Operations and:Maintenance Cost
OAK -Resins - Fayetteville, North Carolina
S&W Job No. 40159.10 .
• -: - - • _• _ - .' • - His - ": . . -_ • : - • • - .- , - - " - - • . .
-
Alternative NO.'. 5 7Disekat'ke- Titated:WateWateetO:Feiyet.iii)ille PWC'E-Systeiti:::
— - - ----—.
, • . .. . . . .... . .. .. . . • - :.. • ,. ...,„ . , .. .....
_ Him -. I
. Description „ - _ I Quantity -I Units I Unit Cost
I ' . 'Cost
" ., , • .: . . ..: " . - . • - . : : :. . .. . , , ,. .
1
POTW Cost for treatment -..flOw based L normally t00% of time
400 :
1;000 gpd $ 3.29 $- 385,000
2
POTW Cost for treatment BOD.based- normallyoftime 80% otithe
. .0
'
lbs/ilaY $ 0.3115 $
3
POTW Cost for treatment --BOD based 'Oak discharge20% of time
. .
0
lbstclay $ 0.3115 $
4
POTW Cost for treatment 7 TSS based 7 none normally
0
lbs/day $ 0.1342 " $ -
5
POTW Cost for treatment - TSS based t peak discharge 20% of time
0
lbs/day $ 0.1342 $ _
6
....
Electricity - based on 5 thonthS of billin5 reaords prorated .i or one year
0
kWh $ 0.045 . $ 276,000
7
Nutrients
1
LS $ 30,000
8
Chemicals
1
LS •$ 195,896
9
Maintenance
1
LS $ 100,000
10
Solids Disposal
1
LS $ 130,000
11
Lab Expense
1
LS $ 156,000
12
Administrative .
. . . .. .
1
LS $ 120,000,
0pinion of Probable Operations and Maintenance Cost
, '$- , . ' l,.392,896.
• SteitrUS-&-Wheler, PLLC
cpx.1 Environmental EngineersAnd

October 21, 2004
Mr. Jeffrey C. Richardson
DAK Americas
3500 Daniels Road, NE •
Leland, North Carolina 28451
Subject:
Dear Mr. Richardson:
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural'Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
DEN 0
OCT 2 8 2004
DWQ
Engineering Alternatives Analysis/DAK Americas
NPDES Permit No. NC0003719
Cumberland County
Members of the Point Source Branch of the Division of Water Quality, along with the Fayetteville
Regional Office, have reviewed the Engineering Alternatives Analysis (EAA) submitted by Stearns &
Wheeler on behalf of DAK Americas. The EAA was required as part, of the ownership change from
Monsanto to DAK Americas [ref. Condition A. (5.) of the NPDES permit] and subsequently stated in the
permit name/ownership change dated June 7, 2004.
We appreciate the manner in which Stearns & Wheeler put together the EAA. The document
outlined the majority of issues discussed in the meeting held with you and Ms. Mahoney on July 6 of
this year. Due to the complexity of the issues with regard to continued discharge versus connection to
PWC Rockfish Creek, we would like DAK to outline some aspects of the EAA iri further detail. The exact
issues are outlined below:
• In the meeting held July 6, there was discussion about the types and percentages of flow being
discharged from the facility. Please document how much flow is related to each facility (DAK and
DTF) and the amount/types of process flow, non -contact cooling water, domestic flow, etc. for
each. If exact numbers are not known, please indicate where estimates are used. Both typical
average flows and maximum flows should be provided.
• Please provide detailed documentation of the BOD5 and TSS values used to determine costs
(especially with regard to discharge to PWC).What values were estimated for no treatment,
partial treatment, etc.?
• DAK should provide documentation from PWC stating how much flow it can accept from the
facility and potential BOD5 and TSS limits (and any other limit requirements).
• Alternative 3 may be eliminated from consideration if DAK can provide written confirmation that
PWC will not accept untreated wastewater.
• The present value costs of operation and maintenance for each alternative should be based on a 20
year period. Also, please use the current EPA discount rate (this may be found at
http://www.nccgl.netJfap/cwsrf/201gui.html; the current rate is 5.625%, but was supposed to
have been updated effective October 1).
• For Alternative 5, please provide detailed documentation on costs. We are unsure how Stearns &
Wheeler arrived at the electrical costs. Additionally, we would think that both electrical costs
and laboratory/chemical costs would be significantly lower than those for Alternative 1 (since
less stringent limits would likely have to be met with a discharge to PWC - laboratory costs and
process control could be reduced; also, the treatment plant might not have to be run at the
same level as that required to meet the more stringent NPDES limits).
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

Mr. Richardson
Page 2
• For Alternatives 4 and 5, please outline how the flow and costs were developed, and why they
would be different.
If you or your consultants have any questions regarding this letter, please contact Susan Wilson
at (919) 733 - 5083, extension 510 or via Susan.A.Wilson©ncmail.net.
Sincerely,
David A. Goodrich, supervisor
Point Source Branch
cc: y_etteville_RegionaLDfficei .Water -Quality -Section •
NPDES Unit
• Central Files
Dana Folley, PERCs (Pretreatment)
Ms. Penny Mahoney, DAK Americas (same address as above)
Ms. Alexandra Kantardjieff, P.E., DEE.
Stearns & Wheeler, PLLC
3128 Highwoods Boulevard, Suite 140
Raleigh, North Carolina 27604

41
DAK Americas
FIBERS, MONOMERS & RESINS
December 8, 2004
Mr. David A. Goodrich, P.E.
Point Source Branch
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Engineering Alternatives Analysis (EAA)
DAK Resins, LLC
Cumberland County
NPDES Permit No. NC0003719
Dear Mr. Goodrich:
D NW -FRO
DEC 2 12p0I
DWQ
This letter is being submitted to address the comments in the letter dated October 21,
2004 from the Point Source Branch of the Division of Water Quality (DWQ) for the
above referenced project. We have reiterated the questions presented in the October 21s`
letter prepared by DWQ followed by our responses. Our responses can be found in
Amendment 1. We request DWQ consider the responses in this letter an amendment to
the EAA dated August 26, 2004.
If you have any questions or need additional information, please do not hesitate to contact
myself at 910-371-5082 or Penny Mahoney at 910-371-5232.
Respectfully , itted,
l7
Jeff Richardson
,./DAK Americas
Attachments
Cc: Penny Mahoney — DAK Americas
Alexandra Kantardjieff, P.E., DEE — Stearns & Wheler, LLC
Susan Wilson, NCDWQ
Paul Rawls, NCDWQ Fayetteville Regional Office DAK Americas, LLC
File Room 3500 Daniels Road, N.E. • Leland, NC 2845 I
1-877-432-2766

AMENDMENT 1
1) In the meeting held July 6, there was discussion about the types and percentages
of flow being discharged from the facility. Please document how much flow is
related to each facility (DAK and DTF) and the amount/types of process flow,
non -contact cooling water, domestic flow etc., for each. If exact numbers are not
known, please indicate where estimates are used. Both typical and average flows
should be provided.
The wastewater flow contribution from both facilities is provided in the industrial
wastewater survey and permit application report prepared by the Public Works
Commission of the City of Fayetteville (PWC). This report was included in Appendix B
of the EAA. Approximately 67 percent and 33 percent of the wastewater flow is
generated by. DTF and DAK, respectively. The average and maximum flows from the
various sources are summarized below in Table 1.
Table 1
Wastewater Sources and Composition
4, , , once f _
Oa el.,F10 g
,, ;Ma mum' Flow, gPd
Process Water
65,660
109,100
Washdown Water
2,000
3,500
Domestic — toilets and potable water .
4,100
5,900
Cooling Water, Process Non -Contact
50,000
60,000
Other: Condensate
2,880
4,320
Stormwater
28,620
209,680
Process Generated Water
50,000
100,000
Totals
203,260
492,500
The flows summarized in Table 1 are approximations, which are based on water
consumption records and process requirements at the time of the estimate. The aggregate
influent flow to the wastewater treatment for both facilities (DAK and DTF) and decant
from the sludge storage basin and the sand drying beds is determined from the flow
measurements recorded at the effluent Parshall flume.
2) Please provide detailed documentation of the BOD5 and TSS values to determine
costs (especially with regard todischarge to PWC). What values were estimated
for no treatment, partial treatment, etc.?
The EAA considered three alternatives with respect to discharging wastewater to the
PWC Rockfish Creek Water Reclamation Facility (WRF). The three alternatives
included:
Alternative No. 3 - Discharging untreated wastewater to the Rockfish Creek WRF.
Alternative No. 4 - Upgrading the Cedar Creek WWTP to reduce energy consumption
followed by discharging treated effluent to the Rockfish Creek WRF.
Alternative No. 5 - Discharging the current effluent to the Rockfish Creek WRF.

Attachment No. 1, summarizes the wastewater data for the months of January through
June of 2004. The average values for April through June are expected to be more
representative, since the plant experienced process upset conditions and a equipment
failure with the secondary clarifier from January through March. The wastewater data for
January through June of 2004 in conjunction with the flow data provided in Table 1 were
used to approximate the organic loadings and flows for Alternatives 3, 4 and 5.
Surcharge fees that would be assessed to DAK Americas for flow and specific pollutant
constituents were provided to us by PWC via e-mail. Attachment No.2 includes the e-
mail from PWC for your reference. The $3.29 per 1,000 gallons applied in the EAA for
flow is the industrial wastewater rate provided by PWC. It was also provided to Stearns
& Wheler on August 9, 2004 during a phone conversation with PWC. The surcharge fees
for BOD and TSS are assessed when the effluent concentrations exceed 300 mg/L.
The maximum BOD concentration that PWC will accept is 800 mg/L, according to the
industrial pretreatment permit issued to DAK Americas from PWC. Refer to Attachment
No. 3 for the industrial pretreatment permit issued to DAK Americas from PWC. This
maximum BOD concentration of 800 mg/L is less than the average raw influent BOD
concentration at the Cedar Creek WWTP. As noted in the wastewater data summary, the
plant only measures influent COD. A BOD : COD ratio of 0.53 was applied to convert
the influent COD concentrations to BOD values. The applied ratio of 0.53 is based on an
extensive wastewater characterization study performed at another DAK Americas facility
located in Moncks Corner, SC . with comparable production and wastewater
characteristics.
Surcharge fees for BOD and TSS were not applied for Alternatives Nos. 4 and 5, since
the current average and maximum effluent concentrations do not exceed 300 mg/L.
3) DAK should provide documentation from PWC stating how much flow it can
accept from the facility and potential BOD5 and TSS limits (and any other limit
requirements).
Attachment No. 3 includes an industrial pretreatment permit, which was provided to
DAK Americas from PWC. The permit indicates a monthly average and daily maximum
flow of 0.060 mgd and 0.110 mgd, respectively. Effluent BOD5 and TSS concentrations
indicated in the permit are 800 mg/L and 3 mg/L, respectively.
4) Alternative 3 may be eliminated from consideration if DAK can provide written
confirmation that PWC will not accept untreated wastewater.
Alternative No. 3 is not considered a cost-effective alternative. The surcharge fees that
would be assessed to DAK Americas are cost prohibitive given the nature of the raw
wastewater, regardless of whether, or not, the Fayetteville PWC accepted DAK's
untreated wastewater.

5) The present value costs of operation and maintenance for each alternative
should be based on a 20-year period. Also, please use the current EPA discount
rate (this may be found at http://www.nccal.net/fap/cwsrf/201gui.html; the
current rate is 5.625% but was. suppose to be updated effective October lst).
The present value costs presented in Table 4-3 of the EAA have been updated based on
an interest rate of 5.625% and a return period of 20 years.
Table 4-3 (Revised)
Opinion of Probable Present Worth
Opinion
"X r of , ��FV
% ,Cost
r ` s R ' ri xAlternrative
� `z���.No��l; ���'���1�Io'
2 ��" r�;
� HNq_,
T7o 4 .....
` . 1\TQ 5 a
Capital Cost
$0
$960,000
$0
$960,000
$0
O&M Cost
$1,007,896
$640,000
$1,380,000
$1,160,000
$1,393,000
Present
Value
$12,000,000
$8,500,000
$16,400,000.
$14,700,000
$16,500,000
Alternative No. 3 can be eliminated from consideration, since the average raw influent
BOD concentrations exceed the maximum BOD concentration accepted by PWC.
6) For Alternative 5, please provide detailed documentation on costs. We are
unsure how Stearns & Wheler arrived at the electrical costs. Additionally, we
would think that both electrical costs and laboratory/chemical costs would be
significantly lower that those for Alternative 1 (since less stringent limits would
likely have to be met with a discharge to PWC — laboratory costs and process
control limits could be reduced; also, the treatment plant might not have to be
run at the same level as that required to meet the stringent NPDES limits).
Alternative Nos. 1 and 5 are based on using the existing equipment, since the equipment
is required for both treatment and mixing. Therefore, the electrical costs are expected to
remain identical for both alternatives. The average power consumption for the
wastewater treatment facility is 700 kWH, according to DAK Americas. The average
electricity cost for January. through June was $0.0444 per kWH, as shown in Attachment
No. 4. This electrical cost in conjunction with the 700 kWH was used to calculate the
annual electrical cost for the wastewater treatment facility.
The annual laboratory cost of $156,000 applied in the EAA was based on past expenses
incurred by DAK Americas. The annual cost for lab analysis is not anticipated to vary
significantly considering both permits have comparable monitoring requirements. For
example, even if the annual lab cost for Alternative No. 5 were 50 percent of that which
is required for Alternative No. 1 the 20-year present worth value for Alternative No. 5
would still be approximately $15,600,000.
7) For Alternatives 4 and 5, please outline how the flow and costs were developed,
and why they would be different.

•
Alternative No. 4 considers upgrading the wastewater treatment facility to reduce annual
O&M costs compared tomaintaining the current operational practices, as described by
Alternative No. 5. Both alternatives could produce effluent in compliance with DAK's
current NPDES permit limits. The maximum flows, recorded by the facility from January
2004 to June 2004, rounded to 400,000 gallons per day were used in each case. It is our
opinion that maximum flows must be used in this analysis, and not average values.
Discharge of all wastewater to Fayetteville PWC will be required 100 percent of the time,
even in case of upset conditions.
We would like to ask you very kindly to correct one typo error that is shown in Appendix
F on the table showing the O&M costs for alternative No.5. Under item 6 (electricity) the
quantity should read 700 kWh, and not 0. The total cost was calculated with 700 kWh.
Attached is the corrected table reflecting this change and can be found in Attachment 5.
Please replace this page in the EAA.

ATTACHMENT NO. 1
Wastewater Characteristics (January through June 2004
} „i, ,1
Minimum
Avera e g
Maximum
Minimum
Average
Maximum
Parameter
'n °}upsets
,1
u,,.,
Excluding
Excluding
{Upsets
7 a ♦-7 ^7g:;,nYrE
conditions ._r,'
Excluding
Upsets
h
conditions rrw
Including
upsetst
r �. ..
,conditions '
Including
Upset<
.. ..r
!conditions .
Yncludmg
Upset
`.
conditions
.s, i `
conditions.
Flow (gpd)
0*
231,000
416,000
0*
231,000
416,000
TSS (mg/1)
5
183
1,170
2
17.5
86
COD (mg/1)
2,240
4,746
12,740
2,200
9,995
58,900
COD (1b/d)
1,848
6,615
18,919
105
12,850
110,653
pH
-.
5.2
7.61
3.9
7.47
11.89
* Clarifier shut down

ATTACHMENT NO. 2

rrom:
•ent:
To:
Subjept:
BCD:
{Tot
TSS:
{Tot
NH3:
{Tot
Rob Allen [[e-mail]]
Monday, August 09, 2004 11:28 AM
akantardj [e-mail]
Surcharge Rates
IF({Average Sample Result}
1 Flow by volume}(G(M)]
IF({Average Sample Result}
1 Flow by volume) [GM].
IF({Average Sample Result}
1 Flow by Volume) [G (M) ] *
Rob ;lien
Sy�st m Protection Supervisor
Public.Works Commission
Phone: [phone]
Ce11 910-263-1434'
Page : 910-677-3526
Fax: [phone]
Emai : [e-mail]
Webs te: www.faypwc,com
[mg/L] > 300,((({Average Sample Result}[mg/L]-300)*8.34)*
0.31150),0 )
[mg/L] > 300, ((({Average Sample Result} [mg/L] •300) *8.34) *
0.13420),0 )
[mg/L] > 50, ((({Average Sample Result} [mg/L] -50) *8.34) *
0.68560),0 )
CletAgir .
100aut_ - - -- 2 4
17 °Co:o 61.Mi0105
1. t ®O�

ATTACHMENT NO. 3

•
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 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the City of Fayetteville.
DAK Resins, 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: 0
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 [INSERT DATE].
This permit and the authorization to discharge shall expire at midnight on [INSERT DATE].
Signed this day of , 2004.
Permit Number 2116RF
40 CFR Category 414
Steven K. Blanchard, General Manager
Public Works Commission
City of Fayetteville
North Carolina

IU Name: DAK Resins.LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
Supplement to Permit Cover Sheet
DAK Resins, 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, Comminutor Pit, Existing
Lift Station, Sample Point, 2 EQ Tanks, pH Adjustment Pit, Aeration Basin; 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 Resins, 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 Resins,LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
3

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Resisns, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
A. 1. Description of Discharge(s)
Pipe Number Description
01 Process wastewaters; Equipment/facility washdown;
Domestic; Non Contact Cooling water; stormwater
run-off that has come in contact with OCPSF
regulated wastestreams, to sewer (After pretreatment)
- all regulated under 40 CFR Part 414 - the Organic
Chemicals, Plastics, and Synthetic Fibers Category.
(Thermosetting Resins & Commodity Organic
Chemicals).
2. Location of Monitoring Point(s)
See attachment.
Pipe 01
After final pretreatment stages, sample to determine compliance with OCPSF (40
CFR 414) standards is to be drawn from [ ]

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
3. DAK Permit Modification History
IU Name: DAK Resisns, LLC
Permit#: 21.16RF
Pipe#: 01
40 CFR#: 414
a. Original Permit issued on [INSERT DATE] expires [INSERT DATE].
5

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Resisns, 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#: NC0050105
Effective Date for These Limits: Effective Date of this Permit
Expiration Date for These Limits: Expiration Date of this Permit
Pipe #: 01 - 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.
Limited Parameter
Effluent Limitation
in Ibs/day(*2) `
Sample'
Type
Composite
or Grab
Monitoring
Frequency
,_ Daily.
Maximum
Monthly
Average
by °'
Permittee.
By : PWC
acenaphthene
0.174
Grab
1/6 Months
1/ Calendar Year
Anthracene
0.174
Grab
1/6 Months
1/ Calendar Year
Benzene
0.495
Grab
1/6 Months
1/ Calendar Year
Bis phthalate
0.952
Grab
1/6 Months
1/ Calendar Year
carbon tetrachloride
1.403
Grab
1/6 Months
1/ Calendar Year
Chlorobenzene
1.403
Grab
1/6 Months
1/ Calendar Year
Chloroethane
1.089
Grab
1/6 Months
1/ Calendar Year
Chloroform
1.200
Grab
1/6 Months
1/ Calendar Year
Di-n-butyl phthalate
0.159
Grab
1/6 Months
1/ Calendar Year
1,2 dichlorobenzene
2.931
Grab
1/6 Months
1/ Calendar Year
1,3-dichlorobenzene
1.403
Grab
1/6 Months
1/ Calendar Year
1,4-dichorobenzene
1.403
Grab
1/6 Months
1/ Calendar Year
1,1 DCA
0.218
Grab
1/6 Months
1/ Calendar Year
1,2 DCA
2.119
Grab
1/6 Months
1/ Calendar Year
1,1 DCE
0.222
.
Grab
1/6 Months
1/ Calendar Year
1,2 trans DCE
0.244
Grab
1/6 Months
1/ Calendar Year
1,2 Dichloropropane
2.931
Grab
1/6 Months
1/ Calendar Year
1,3 Dichloropropene
2.931
Grab
1/6 Months
1/ Calendar Year
Diethyl phthalate
0.417
Grab
1/6 Months
1/ Calendar Year
Dimethly phthalate
0.174
Grab.
1/6 Months
1/ Calendar Year
4,6 Dinitro-o cresol
1.023
Grab
1/6 Months
1/ Calendar Year
Ethylbenzene
1.403
Grab
1/6 Months
1/ Calendar Year
Fluoranthene
0.199
Grab
1/6 Months
1/ Calendar Year
Fluorene
0.174
Grab
1/6 Months
1/ Calendar Year
Hexachlorobenzene
2.931
Grab
1/6 Months
1/ Calendar Year
Hexachlorobutadiene
1.403
Grab
1/6 Months
1/ Calendar Year
hexachloroethane
2.931
Grab
1/6 Months
1/ Calendar Year

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Resisns, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. B.1.EFFLUENT LIMITS AND MONITORING REQUIREMENTS
Pipe #: 01 - Regulated (OCPSFI under 40 CFR 414 (continued
Limited Parameter
Effluent Limitation
r' in Ibs/day(*2) _
Sample
Type
Composite ^
or Grab
Monitoring`
Frequency'
Daily .
Maximum
Monthly.
Average
' by
Permitted -
P1NC:�,
Methyl chloride
Grab
1/6 Months
1/ Calendar Year
Methylene chloride
Grab
1/6 Months
1/ Calendar Year
Naphthalene
Grab
1/6 Months
1/ Calendar Year
Nitrobenzene
Grab
1/6 Months
1/ Calendar Year
2-Nitrophenol
Grab
1/6 Months
1/ Calendar Year
4-Nitrophenol
Grab
1/6 Months
1/ Calendar Year
Phenanthrene
Grab
1/6 Months
1/ Calendar Year
Pyrene
Grab
1/6 Months
1/ Calendar Year
Tetrachloroethylene
Grab
1/6 Months
1/ Calendar Year
Toluene
Grab
1/6 Months
1/ Calendar Year
Total Cyanide
Grab
1/6 Months
1/ Calendar Year
Total Lead
Grab
1/6 Months
1/ Calendar Year
Total Zinc
Grab
1/6 Months
1/ Calendar Year
1,2,4 Trichlorobenzene
Grab
1/6 Months
1/ Calendar Year
1,1,1 TCA
Grab
1/6 Months
1/ Calendar Year
1,1,2 TCA
Grab
1/6 Months
1/ Calendar Year
TCE
Grab
1/6 Months
1/ Calendar Year
Vinyl chloride
Grab
1/6 Months
1/ Calendar Year
7

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Resisns, 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: May 13, 2002
Expiration Date for These Limits: June 30, 2005
Pipe #: 02 - 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.
Flow
Effluent Limitation
in ing/L
0.110MGD
0.060MGD
Continuous (*2)
Monitoring..::
=Frequency
1/6 months
BOD
TSS
800
*3
800
*3
Composite
Composite
1/ weekly
1/ month
1/6 months
1/6 months
Ammonia
*3
*3
Composite
1/ month
1/6 months
Oil & Grease
250
Grab
1/ month
1/6 months
Total Phos.
3
Composite
1/6 months
1/6 months
pH
*1
Grab
1/ weekly
1/6 months
Arsenic
*3
Composite
1/6 months
1/6 months
Cadmium
Chromium
Copper
Cyanide
*3
*3
*3
*3
Composite
Composite
Composite
Grab
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
Lead
Mercury
Molybdenum
Nickel
*3
*3
*3
*3
Composite
Composite
Composite
Composite
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
Selenium
Silver
Zinc
*3
*3
*3
Composite
Composite
Composite
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
1/6 months
Phenol
*3
Grab
1/6 months
1/6 months
See Page 9 for Limit Page Notes and Page 11 for Defmitions.
8

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
Limits Page Notes:
IU Name: DAK Resisns, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
*1 The pH shall not be less than 6.0 or greater than 10.0 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. Permittee shall monitor these pollutants during the first
and third quarters of each calendar year. If monitoring results indicate the presence
of pollutants in amounts which 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.
9

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
C. Monitoring and Reporting
1. Representative Sampling
IU Name: DAK Resisns, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
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.
2. 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 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 Division of Environmental
Management 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 Resisns, 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 pennittee 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 pennittee 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 who performed the analysis.
7. Definitions
a. A composite sample, for monitoring requirements, is defined as a minimum
of four (4) grab samples collected at equally spaced two (2) hour intervals
(during an 8-hour workday), or once every two (2) hours if facility runs
continuously for 24-hours. Sampling day shall be a typical 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 Resins, 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. -
C. 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 pennittee shall
identify to the PWC the hazardous/toxic waste hauler used for removal of such
substances and notify the PWC of any change of said hauler.
12

PART II. IU Name: DAK Resins, 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 to provide 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 recordsas 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 Resins, 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, Section 31-68, 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 a ranking official or duly authorized agent of the permittee.
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.
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.
14

PART II. IU Name: DAK Resins, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
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 $10,000.00 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 pennittee 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 more than six (6) months, or by both.
P. Transfer of Discharge Permit
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.
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.
15

PART II. IU Name: DAK Resins, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
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 approval and an Authorization to Construct have been issued by the
PWC.
Sludge Management Plan
Within 90 days prior to the initial disposal of sludge generated by any pretreatment
facility, the permittee shall submit a sludge mangement plan to the PWC's
Pretreatment Program .Office.
16

PART II. IU Name: DAK Resins, 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 altematively, 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 is responsible for contacting the PWC by telephone inunediately 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 describing the cause 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 31-53).
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 Resins, 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 5.0, 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 which 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, nonbiodegradable 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.
18

PART II. IU Name: DAK Resins, 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.
SPECIAL PERMIT
CONDITIONS
PART III. SPECIAL PERMIT CONDITIONS
Biotoxicity Monitoring
IU Name: DAK Resins, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
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 perinittee's effluent
toxicity shall determine the frequency of the Biotoxicity monitoring.
B. Toxicity Control
Upon determination of toxicity in the pennittee's effluent, the permittee shall be
required to identify and eliminate the source(s) of the toxicity from the final
discharge.
C. Periodic Reports on Continued Compliance
DAK Resins, LLC shall submit to the Public Works Commission a biannual
"Periodic Compliance Report" that states whether or not applicable OCPSF standards
are being met on a consistent basis, during the months of June and December. The
report shall indicate the precise nature and concentrations of the regulated pollutants
in its discharge to PWC, the average and maximum daily flow rates of the facility,
the methods used by DAK to sample and analyze the data, and a certification that the
methods used conform to those methods outlined in the OCPSF regulations.
D. Flow Monitoring
The Public Works Commission shall use the flows registered on the permittee
effluent flow meter for the purpose of flow limit compliance. The permittee will be
required to submit records of daily wastewater discharge to PWC no later than the
twenty-fifth (25th) of each month. These records shall contain daily wastewater
discharge flows for the period of the sixteenth (16th) of one month through the
fifteenth (15th) of the following month.
E. 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 Tejin Films must continue
to work together to ensure that the conditions of this permit are met.
20

PART III. IU Name: DAK Resins, LLC
SPECIAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
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 finalization 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.
21

PART III. IU Name: DAK Resins, LLC
SPECIAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
The flow meter shall be calibrated once during each six-month period 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:
a. Increase or decrease in sewer flow greater than twenty-five percent (25%) in
two consecutive months.
b. Increase or decrease in "sewer flow to water consumption" ratio above 10
percent in two consecutive months.
PWC shall be notified within 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 Public Works Commission shall use flow readings from the dedicated lift station
that services the DAK site for sewer billing and surcharge calculation. Compliance
with the OCPSF limitations outlined in Part I.B.1. of this permit shall be based on
actual process flows recorded at the time of OCPSF sample collection.
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.
22

PART III. IU Name: DAK Resins, LLC
SPECIAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
• Procedures for immediately notifying the POTW of slug discharges that would cause
a violation of 40 CFR 403.5(b) (see General Condition 29, Page 14), 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.
23

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 Resins, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
Receiving POTW name:
Rockfish Creek Water Reclamation Facility
POTW NPDES#:
NC0050105
IUP Name:
DAK Resins, LLC
IUP Effective Date:
[INSERT DATE]
IUP Expiration Date:
[INSERT DATE]
B. IU Survey & Application form
Attached is a completed copy of the Industrial User Wastewater Survey &
Application Form.
IU Inspection form
Attached is a copy of the most recent Industrial User Inspection.
24

PART IV.
PERMIT SYNOPSIS
IU Name: DAK Resins, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
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
25

ATTACHMENT NO. 4
$35, 000.00
$30, 000.00
$25, 000.00
$20, 000.00
$15, 000.00
$10, 000.00
$5,000.00
$-
Waste Treatment Electrical Costs
January • February March • April May June

ATTACHMENT NO. 5

Opinion of Probable Operations and Maintenance Cost
DAK Resins - Fayetteville, North Carolina
S&W Job No. 40159.10 -
Alternative No. 5 - Discharge Treated Wastewater to Fayetteville PWC's System
.. j. r - f
.. 5,.... ..,.
Item- - `,?r
_. .F, :, ,:Description i { _. �`. - _ ,..., n�
Quantity
nits
Unit Cost
Cost, .
1
POTW Cost for treatment - flow based - normally 100% of time
400
1,000
gpd
$ 3.29
$385,000
2
POTW Cost for treatment - BOD based - normally 80% of time
0
lbs/day
$ 0.3115
$ -
3
POTW Cost for treatment - BOD based - peak discharge 20% of time
0
lbs/day
$ 0.3115
$ -
4
POTW Cost for treatment - TSS based - none normally
0
lbs/day
$ 0.1342
$ -
5
POTW Cost for treatment - TSS based - peak discharge 20% of time
0
Ibs/day
$ 0.1342
$ -
6
Electricity - based on 5 months of billing records prorated for one year
700
kWh
$ 0.045
$ 276,000
7
Nutrients
1
LS
$ 30,000
8
Chemicals
1
LS
$ 195,896
9
Maintenance
1
LS
$ 100,000
10
Solids Disposal
1
LS
$130,000
11
Lab Expense
1
LS
$ 156,000
12
Administrative
1
LS
$ 120,000
fFa tiro
ar !C t,.r
,% t ✓5 Y9 i,
v..Y� 'A,n,�,,,, s ai r �`�.+' 7� ',"
3 ,4t "-s+' a` XS 7^ tip` a 3 it y fi St i
T
axe 5 T
t _� 4
fi d ado a ,fix
t " '� t i -- it i ✓ ,
:,
.,i
S
3 a t
Y
su `x".
e J
..
-
in
Opion of
✓ are
Orobaabl
eration
ptnd
Maintenance
C Wy.
,.. .Co$t
$1,392,896