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Home My WebLink AboutNC0003719_Name Change_20040715DAK Americas fiFV FIBERS, MONOMERS & RESINS July 15, 2004 Mrs. Susan Wilson North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 JUL 2 3 2004 Dw* Subject: NPDES Permit Modification Name/Ownership Change Permit NC0003719 DAK Americas Cedar Creek Site Dear Mrs. Wilson, Thank you and the Division for meeting with DAK Americas on July 6, 2004 to discuss your letter dated June 7, 2004 regarding the Cedar Creek Site NPDES Permit (NC0003719) transfer issues. In the June 7 permit letter, the state requested DAK to submit a major permit modification and an Engineering Alternative Analysis (EAA) within 60 days of receipt of the new permit. In the July 6th meeting, the state agreed that DAK was not to submit a major permit modification at this time. The state agreed that DAK did not have to complete the land disposal section of the EAA but would complete the remainder of the analysis. The state agreed that DAK would submit the major permit modification after the state reviewed the EAA. At the Division's request, DAK Americas agreed to submit an Engineering Alternative Analysis (EAA). DAK asked for some additional time to submit the EAA in order to get an external consultant to complete the analysis. As discussed on the phone this morning, we would like to request a submittal date for the EAA of August 26, 2004. Once the Division has reviewed the EAA, another meeting will be scheduled to discuss the next step in the permit modification name/ownership change. If DAK's understanding of the agreed upon timing and pathforward is incorrect, or if you'have any question or concerns please contact me at 910-371-5082 or 910-262-2288. Cc: File Room Paul Rawls, NCDWQ Fayetteville Regional Office Ms. Penny Mahoney, DAK Americas DAK Americas, LLC 3500 Daniels Road, N.E. • Leland, NC 2845I 1-877-432-2766 www.dakamericas.com • 1 i ; 1 , • 1 • , 1 i 1 1 • 4+ NANAkl...±..,-- ....-,---• ..... •-...... ite7 &11..,‘T* ' NW* No . ___—.... . 7L03, -0S.3 eiti, 5/0 7 • 301r1V, 4 oxfs.sopf 6 lteimay.. Id . :i re.latvGew eckkAblier;cA e— ; 1 Ave a. c 0 Al pKicH Qb4/14---70e5 wco 7--5&F3 x...c717 ii /, 444Lecbiai e #cmet/k/ /los- il -.! cr .-1-1-- 1 ' f - i fr--s--?-1.___ /,',/e---C-S' • ..9/.' -? 4 Co t CA 1 TA P i , . eQ,,k IQ_. NcIA,c,l, .111i r4 mei. i ii il il il li \ 11 li Il 1 il 1 11 FIggR§; 1"igNr.J4"1gR§ gi Rg§IN§ Cedar Creek NPDES Permit Meeting a OAK Anitrica§ Fittm;118C18I R§ « §IN§ Agenda e PWC History/Financials/Summary s DAK Proposal e Discussion DAIS Amrkae PWC History flgE11§; MgNeil€ § KE§IN§ - Mid 2001 - Monsanto notified DAK and DTF that they were going to shutdown their manufacturing facilities. Offered utility facilities for purchase to either DTF/DAK. Both declined. Services to be cut off between 12/03 and 6/04. - Late 2001 - Monsanto threatened to cut off WWT services prior to contract if buyer for plant could not be found. - November, 2001 - DAK/DTF began discussions with PWC on possibility of their treating DAK/DTF wastewater. • PWC could take wastewater only if it were pre-treated to reduce COD and if site could minimize flow - 2002 - Monsanto found a potential buyer but buyer would not take over responsibility for wastewater treatment. - PWC received -$800,000 grant to install header out to DAK/DTF complex. - Late 2002 - Monsanto deal fell through due to concerns over future environmental liability. - Early 2003 - DAK/DTF began discussing purchase. DAK agreed to purchase for betterment of the overall complex. - December 17, 2003 - Purchase finally completed. - PWC header well into construction at this point. DAK Americas PWC Financials • Cost to run header to tie-in to PWC - $750,000. Currently being installed. • Water must be pre-treated so many of the costs of the current wastewater plant will continue. • PWC cost per gallon of water without any surcharges will exceed $250,000/year. • Surcharges will occur if excessive flow, COD or TSS. • Storm water and excess flow will have to be discharged to the Cape Fear River from DAK facility. DAK AmrIcas FIg€K§; M@NN€K§ H§IN§ PWC Summary 8 DAK believes that we are obligated to tie-in to the PWC header in order to repay the county for installing the header when the facility was in need. 8 However, ongoing cost to dual -treat water will be prohibitive to the current businesses 8 Despite the availability of many other services at the site, additional growth at the site would be precluded due to the flow limitations of PWC. 8 There is no benefit to the river whether the water is discharged via PWC or through the DAK's facility. OAK America§ DAK's Wastewater Operations Proposal ®AID Anwrica§ 418N811WM « Rt§IN§ • Initial Operation • Operate under existing permit with no changes to effluent limitations and a permitted discharge of 0.5 MGD. .I Continue to discharge stormwater from Outfall #002. a PWC Operation (expected 4th Qtr 2004) • Operate under existing permit with no changes to effluent limitations and a permitted discharge of 0.5 MGD. Permit cooling tower blow -down to discharge to a stormwater outfall. • Future Operations • Decrease flow to PWC and allow more water to discharge from DAK facility until all flow to PWC has been stopped. ® In all cases, keep 1.25 MGD allocation for future expansion and other businesses to be located on -site. MKArn Pic DAK's Proposed Pathforward • DAK to submit $860 and a permit modification to allow for cooling tower blow -down directly to Outfall. — DAK should not need to resubmit complete permit modification for current operations because there is no change to what was previously submitted by Monsanto. • DAK will submit a complete major permit modification and an Engineering Alternative Analysis when requesting to increase discharge to the 1.25 MM gallons.