NC0003719_Engineering Alternatives analysis_20041208

NPDES DOCIMENT !;CANNING COVER SHEET
NC0003719
Cedar Creek site WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Monitoring Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
December 8, 2004
This document is printed on reuse paper - ignore any
content on the reYerse side

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:
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 21 st
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
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 28451
1-877-432-2766
www.dakamericas.com

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 Comuosition
.f.
x " ilgate L4 eri,Hw�`9'
60MiSa .T1
' •.: „ unt, O;3td
-Process Water
,WCAM
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 BUDS and TSS values to determine
costs (especially with regard to discharge 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 -
Alternative No. 4
Alternative No. 5
Discharging untreated wastewater to the Rockfish Creek WRF.
- Upgrading the Cedar Creek WWTP to reduce energy consumption
followed by discharging treated effluent to the Rockfish Creek WRF.
- 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 Steams
& 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.nccgl.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
of Cost
Alternative !
No. 1
No. 2
No. 3
No. 4
No. 5 l
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 to maintaining 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)
Minimum
Average
Maximum
Minimum
Average
Maximum
Parameter
Excluding
upsets
conditions
Excluding
Upsets
conditions
Excluding
Upset
conditions
Including
upsets
conditions
Including
Upset
conditions
Including
Upset
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 (lb/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

Alex4ndra Kantard !eff
'rom:
•ent:
To:
Subjeft;
SOD!
{Tot
TSS:
{Tot
NH3:
{Tot
Rob Allen [[e-mail]]
Monday, August 09, 2004 11:28 AM
[e-mail]
Surcharge Rates
IF({Average Sample Result}
1 Flow by volume } (G (M) ]
IF({Average Sample Result}
1 Flow by volume } [G (M) ]
IF({Average Sample Result}
1 Flow by Volume } [G (M) ]
Rob Allen
System Protection Supervisor
Public Works Commission
Phong: 910-223-4699
Ce11 910-263-1434'
Page
Fax:
Emai:
Webs-
: 910-677-3526
910-483-1153
: x'ob . allen®faypwc . com
te: www.faypwc.com
[mg/L3 > 300, ((({Average sample Result} (mg/L: -300) *8.34) *
0.31150) , 0 )
[mg/L3 > 300, ((({Average Sample Result} [mg/L] -300) *8.34) *
0.13420),0 )
[mg/L3 > 50, ((({Average Sample Result} [mg/L] -50) *8.34) *
0.68560),0 )
QwQ'r =>
YL.'G-UL } ,, 20W
it000edtan
I?00 0 6►A-titorI

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:
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.
Steven K. Blanchard, General Manager
Public Works Commission
City of Fayetteville
North Carolina
Permit Number 2116RF
40 CFR Category 414

IU Name: DAK Resins1LC
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 [
4

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
3. DAK Permit Modification History
IU Name: DAK Resisns, LLC
Permit#: 2116RF
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.
'
LimteParameer
i .R. }# Y.I
Effluent` .. miiatiot ,
Ibs/day( )JpI
t1 t 7L } ,
: :
.; 4 t
11 o itonng=
, . �:u�:�. u..,:.ti; Frequency,
a Dl
aximumAverageGab1
Mn y
osite
Jl��-r� tt
.Pee.riii
-�=sT.f"l'.I- r _
, UV
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
6

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Resisns, LLC
Permit#: 21 16RF
Pipe#: 01
40 CFR#: 414
PART I. B.1.EFFLUENT LIMITS AND MONITORING REQUIREMENTS
1. Pipe #: 01 - Regulated (OCPSF under 40 CFR 414 (continued).
Limited Parameter
Effluent Limitation
in Ibs/day(*2)
Sample
Type
Composite
or Grab
Monitoring
Frequency
Daily
Maximum
Monthly
Average
by
Permittee
by
PWC
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 Favetteville's Sewer Use Ordinance.
Effluent Limitatlon
i S iF
In mg/L F _ ....
Sample:
Type
Monitoring
Frequency,
Limited �'
Parameter
. _
--
Dai1 y
lmu ;
Max m
- -�
Month ; <
8 , rage.
-:' A.^verage
r Composite
gr Graf►,
Y *
Permittee, 4)
Flow
0.1 IAMGD
0.060MGD
Continuous (*2)
1/6 months
BOD
800 ,
800
Composite
1/ weekly
1/6 months
TSS
*3 ✓
Jf *3
Composite
1/ month
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
*3
Composite
1/6 months
1/6 months
Chromium
*3
Composite
1/6 months
1/6 months
Copper
*3
Composite
1/6 months
1/6 months
Cyanide
*3
Grab
1/6 months
1/6 months
Lead
*3
Composite
1/6 months
1/6 months
Mercury
*3
Composite
1/6 months
1/6 months
Molybdenum
*3
Composite
1/6 months
1/6 months
Nickel
*3
Composite
1/6 months
1/6 months
Selenium
*3
Composite
1/6 months
1/6 months
Silver
*3
Composite
1/6 months
1/6 months
Zinc
*3
Composite
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 Definitions.
8

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
Limits Page Notes:
*1
IU Name: DAK Resisns, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
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#: 011
40 CFR#: 414
If the permittee monitors any pollutant at the location(s) designated herein more
frequently than required by this permit, using approved analytical methods as
specified above, the results of such monitoring shall be submitted to PWC.
Monitoring results obtained by the permittee and all other reports required herein
shall be submitted to the PWC at the following address:
System Protection Supervisor
Public Works Commission
Post Office Drawer 1089
Fayetteville, North Carolina 28302
6. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit,
the permittee shall record the following data:
a. the exact place, date, and time of sampling,
b. the date(s) the analyses were performed; and
c. the person(s) or approved laboratory who performed the analysis.
7. Defmitions
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 permittee 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 records as well as copies of reports and information used
to complete the application for this permit for at least three years. All records that
pertain to matters that are subject to any type of enforcement action shall be retained
and preserved by the permittee until all enforcement activities have concluded and
all periods of limitation with respect to any and all appeals have expired. These
records include, but are not limited to, production records, wastewater self -
monitoring records, and State and Federal EPA required records.
13

PART II. IU Name: DAK 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#: 011
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 permittee in any enforcement action that it would have
been necessary to halt or reduce the permitted activity to maintain compliance with
the conditions of this permit.
O. Penalties for Falsification of Reports
The City of Fayetteville Sewer Use Ordinance and North Carolina General Statute
143-215 provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required
to be maintained under this permit, including monitoring reports or reports of
compliance or non-compliance shall, upon conviction, be punished by a fine, or by
imprisonment for not 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.
Q. 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.
X. Sludge Management Plan
Within 90 days prior to the initial disposal of sludge generated by any pretreatment
facility, the permittee shall submit a sludge 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 alternatively, revoked and reissued, to comply with
any applicable effluent standard or limitation issued or approved under Sections
302(b) (2) (c), and (d), 304(b) (2), and 307(a) (2) of the Clean Water Act, if the
standard or limitation so issued or approved:
1. contains different conditions or is otherwise more stringent than any effluent
limitation in this permit, or
2. controls any pollutant not limited in this permit.
The permit as modified or reissued under this paragraph shall also contain any other
applicable requirements of the Act.
AA. Reports of Potential Problems
The permittee is responsible for contacting the PWC by telephone immediately of all
discharges that could cause problems to the POTW, including any slug loadings as
defined by 40 CFR 403.5(b). If the permittee experiences such a discharge, they
shall inform PWC immediately upon the first awareness of the commencement of the
discharge. Notification shall include location of the discharge, type of waste,
concentration and volume, if known, and corrective actions taken by the permittee
to prevent future discharges. The permittee shall, within five (5) days of the verbal
notification, submit to the PWC Pretreatment Program Office a detailed written
report 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. IU Name: DAK Resins, LLC
SPECIAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
PART III. SPECIAL PERMIT CONDITIONS
A. Biotoxicity Monitoring
If it is found that the permittee's effluent has a significant toxic impact upon the
municipal wastewater treatment system and/or its receiving stream, the permittee
shall be required, upon written notification from the PWC, to conduct Biotoxicity
monitoring on the effluent being discharged. The severity of the permittee's effluent
toxicity shall determine the frequency of the Biotoxicity monitoring.
B. Toxicity Control
Upon determination of toxicity in the permittee's effluent, the permittee shall be
required to identify and eliminate the source(s) of the toxicity from the final
discharge.
C. 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 Pennittee, 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. IU Name: DAK Resins, LLC
• PERMIT SYNOPSIS Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
City of Fayetteville, North Carolina
Public Works Commission
Industrial Pretreatment Program Permit
PART IV. IUP Synopsis
A. IUP Basic Information
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.
C. 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 01
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

$35,000.00
$30,000.00
$25,000.00
$20,000.00
$15, 000.00
$10, 000.00
$5,000.00
$-
ATTACHMENT NO. 4
Waste Treatment Electrical Costs
$29,179.80
$15,699.60 $16,239.60
$26,528.40
$20,935.80 $21,270.60
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
I
Alternative No. 5 - Discharge Treated Wastewater to Fayetteville PWC's System
Item
Description
Quantity
Units
Unit Cost
Cost
I
1
POTW Cost for treatment - flow based - normally 100% of time
400
1,000
gpd
$ 3.29
- �i
$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
lbs/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
Opinion of
Probable
Operations
and
Maintenance
Cost
$1,392,896

1.
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11

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Opinion of Probable Operations and Maintenance Cost
DAK Resins - Fayetteville, North Carolina
S&W Job No. 40159.10 __
,-
Alternative No. 3 - Dischar, e Untreated Wastewater
to Fayetteville PWC's System
Item
I Description
Quantity
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
3
POTW Cost for treatment - BOD based - normally 80% of' time
POTW Cost for treatment - BOD based - peak discharge 20% of time
3,980
10,200
Ibs/day
Ib.iday
$ 0.31 15v
$ 0.31 15i
$ 363,000
$ 232,000
4
POTW Cost for treatment - TSS based - none normally
0
Ibs/day
$ 0. I342'/
$ -
5
POTW Cost for treatment - TSS based - peak discharge 20% of time
2,500
Ibs/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
Administrat - 1' ' .n
1
LS
$ 120,000
$ 120,000
Opinion of Probable Operations
and Maintenance Cost
S 1,380,000
,r3f/ I,00a bra 13GD I r
tl LTN6
13 azo pe•
x
k!
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Opinion of Probable Operations and Maintenance Cost
DAK Resins - Fayetteville, North Carolina
S&W Job No. 40159.10
Alternative No. 4 - U� _ rade Cedar Creek WWTP and Dischar_ e to Fa ettevil e
stem
POTW Cost for treatment - flow based - normally
2 POTW Cost for treatment - BOD based
3 POTW Cost for treatment - TSS based
4 Electricity
5 Chemicals
6 Solids disposal
7 Lab expense
8 Maintenance and materials
9 Nutrients
10 Administrative
l00% of time
U 't Cost
/L..... oo e OOC) p
400 1,000 gpd 5 3.29 $
0 lbs/day $ 0.3115 $
0 Ibs/day $ 0.1342 $
250 kWh $ 0.045 $
1 LS $ 100,000 $
1,250 lbs/d $ 0.25 $
1 LS $ 156,000 $
1 LS $ 75,000 $
1 LS $
I LS $ 100,000 $
Opinion of Probable O 1 erations . aintenance Cost
480,340.00
99,000
100,000
115,000
156,000
75,000
30,000
100,000
1,160,000

Ohl
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Opinion of Probable Operations and Maintenance Cost
DAK Resins - Fayetteville, North Carolina .
S&W Job No. 40159.10
Alternative No. 5 - Discharje Treated Wastewater to Fayetteville PWC's System
Item I
Description I Quantity' Units l Unit Cost I Cost
1
POTW Cost for treatment - flow based - normally 100% of time 400 . 1,000 gpd $ 3.291$ 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 lbs/day $ 0.1342 $ -
6
Electricity - based on 5 tnonths of billing records prorated for 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
•
Opinion of Probable Operations and Maintenance Cost' S 1,392,896
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