NC0003719_Permit (Issuance)_20090904

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
Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 4, 2009
This docurnent is printed on reuse paper - ignore airy
content on the reirerse side

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I CDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue Division of Water Quality Dee Freeman
Governor Coleen H. Sullins Secretary
Director
September 4, 2009
Craig Leite, Cedar Creek Site Manager
DAK Americas LLC
3468 Cedar Creek Road
Fayetteville, North Carolina 28301
Subject:
Dear Mr. Leite:
Issuance of NPDES Permit NC0003719
DAK Americas LLC — Cedar Creek Site
3468 Cedar Creek Road
Fayetteville, NC 28301
Cumberland County
The Division of Water Quality (DWQ or the Division) hereby issues this permit pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated October 10, 2007,
or as subsequently amended.
With change of ownership documented in February 2005, DAK submitted preliminary
comments on the draft permit on May 08, 2009; met with DWQ on May 22; resubmitted
comments on May 29 including a revised Engineering Alternative Analysis (EAA); and finally,
DAK responded to the DRAFT FINAL with comments received August 18, 2009. Based on this
correspondence and review, the Division offers the following discussion of the permit FINAL:
1. DAK requested that DWQ correct the permit Supplement to Cover Sheet by revising the list of
treatment -system components, and has provided corrections. DWQ has made these corrections.
2. Facility Grade and Related Monitoring. Considering the agreed -to FINAL permitted flow of 0.500
MGD, DAK requests that DWQ reclassify the WWTP from a Grade III to a Grade II, and thereby
decrease the effluent monitoring frequencies from 3/Week to the appropriate 1/Week. The Division
has no objections and has made this change. Likewise, receiving -stream monitoring is reduced to
1/Week - no variation in winter [see permit Section A.(1.)].
3. OCPSF Monitoring. DWQ has previously relaxed most OCPSF monitoring frequencies from
1/Quarter to the current 1/Year based on minimal detection. For renewal based on this analytical
record, DAK requests that DWQ allow DAK to discontinue monitoring of all OCPSF-listed
parameters. DAK sites state regulations granting the Director discretionary authority to honor this
request. However, the Division does not agree that "no monitoring" serves to adequately govern the
receiving -stream environment. DWQ therefore must deny DAK's request. However, based on the
analytical record, DWQ will relax the monitoring frequency of water -quality based parameters [2,6-
Dinitrotoluene (code 34626) and Hexachlorobenzene (code 39700)] and metals from 1/Quarter to
1/Year consistent with the other OCPSF parameters in this permit [see permit Section A.(1.)].

9/3/2009
Issuance of NPDES permit NC0003719
DAK Americas LLC
Page 2 of 3
4. Ammonia Limits and Monitoring. DAK requested that DWQ modify permit limits for ammonia
(NH3 as N), reinstating 35 & 70 lbs/day (summer); 70 & 140 lbs/day (winter), Monthly Average &
Daily Maximum, respectively, from the previous permit (Phase II at 0.500 MGD). These previous
permit limits are in error and were not adjusted proportionally to flow. The Division corrected these
errors for the DRAFT FINAL to 13 & 26 lbs/day (summer); 26 & 521bs/day (winter) consistent
with flow -proportional BOD/NH3 limits since 1989 based on modeling considering receiving -
stream capacity. No changes recommended (see Fact Sheet Addendum 1). Based on monitoring
data from 2005 through 2008, DAK has not exceeded these new NH3 limits and should have no
problem with future permit limit compliance.
5. Permit Limits - Recalculation. For permit issuance, DWQ recalculated draft permit limits and
monitoring conditions using OCPSF-regulated flow only. The Division used the agreed -upon long-
term average of 0.228 MGD, excluding non-OCPSF regulated flow proposed for the plastics
recycling facility (PRF) wastes generated under SIC Code 5162 [see permit section A. (1.)]. DWQ
recalculated OCPSF §414.41 limits as:
Flow (0.228 MGD) x 64 mg/L x 8.34 lbs/gal for Daily Maximum, and
Flow (0.228 MGD) x 24 mg/L x 8.34 lbs/gal for Monthly Average
6. Proposed Plastics Recycling Facility (PRF) — Revised Special Condition A. (5.). Contrary to the
draft permit, PRF construction does not require an Authorization to Construct (ATC) Permit.
However, an ATC is required for any additional treatment units or processes necessary to treat PRF
wastes. Therefore, during construction of the proposed PRF (with process -contact flow estimated at
0.111 MGD), DAK shall designate a sampling location, as Internal Outfall 001, influent to the
onsite WWTP whereby the Permittee may sample and analyze PRF wastes prior to mixing with
other wastes. No later than 180 days prior to receiving wastes from said PRF, DAK will provide a
written report characterizing PRF wastes generated under SIC 5162, in accord with revised permit
Special Condition A. (5.).
7. Total Residual Chlorine (TRC) — A TRC limit has been added to the permit (28 ug/L), consistent
with the new statewide standard for chlorine. However, compliance is required only if chlorine is
used, and because of difficulties quantifying TRC in a wastewater matrix, values detected below 50
ug/L will be considered compliant with this permit [see permit, Part 1. (A.), TRC footnote].
8. Stormwater Outfalls — DAK has requested the Division to combine wastewater point -source
permitting with existing stormwater outfalls permitted under NCS000389. The Division must deny
this request as it moves toward separating wastewater and stormwater permits statewide due to
significant complications governing permit monitoring and renewal. Therefore, all stormwater
outfalls previously attached to this permit are hereby transferred and will be reviewed and renewed
as appropriate under the requirements of stormwater permit NCS000389 (in progress).
If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable,
you have the right to an adjudicatory hearing upon written request within thirty (30) days after receiving this
letter. Your request must take the form of a written petition conforming to Chapter 150B of the North
Carolina General Statutes, and must be filed with the office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such demand is made, this permit remains final and
binding.

W3/2009
Issuance of NPDES permit NC0003719
DAK Americas LLC
Page 3 of 3
This permit is not transferable except after notifying the Division of Water Quality. The Division may modify
and re -issue, or revoke this permit. Please notice that this permit does not affect your legal obligation to obtain
other permits required by the Division of Water Quality, the Division of Land Resources, the Coastal Area
Management Act, or other federal or local governments.
If you have questions, or if we can be of further service, please contact Joe Corporon at
[[e-mail]] or call [phone].
Respectfully,
Coleen H. Sullins
/`
Enclosure: NPDES Permit FINAL NC0003719
Fact Sheet Addendum 2
cc: Fayetteville Regional Office/Surface Water Protection Section, Attn: Mark Brantley
NPDES Program
PERCs Unit [e-copy]
Technical Assistance and Certification Unit [e-copy]
Stormwater Permitting Unit, Attn: Jennifer Jones [e-copy]
Aquatic Toxicology Unit, Attn: Susie Meadows [e-copy]
EPA Region 4, Attn: Marshall Hyatt [permit + application + Fact Sheet Addendum 2]
DAK Americas LLC, Attn: Elizabeth Wike (ORC)
3500 Daniels Road, N.E., Leland, NC, 28451

• • Permit NC0003719
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provision of North Carolina General Statute 143-215.1, 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 Americas LLC
is hereby authorized to discharge wastewater from a facility located at
DAK Americas LLC - Cedar Creek Site
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 October 1, 2009.
This permit and authorization to discharge shall expire at midnight on October 31, 2011.
Signed this day September 4, 2009.
Coleen H. Sullins, Director
J Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0003719,r
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions described herein.
DAK Americas LLC
is hereby authorized to:
1. continue to operate an existing 0.500 MGD wastewater treatment plant (WWTP) consisting of
• flow equalization,
• spill basin
• pH adjustment
• oil skimming
• dual aeration basins
• clarifier
• parshall flume
• sludge pump station
• an aerobic digester
• aerated biosolids holding basin
• biosolids drying beds, and associated equipment
located at the DAK Americas LLC - Cedar Creek Site, 3468 Cedar Creek Road, south of Fayetteville
in Cumberland County, and
2. after constructing a plastics recycling facility (PRF), locate internal PRF Outfall 001 (influent to
the existing WWTP) upstream of any wastewater treatment, and after characterizing the PRF
wastestream and identifying any new wastewater treatment units and/or processes required to
treat PRF process -contact wastes [See Special Condition A. (5.)], apply for and receive an
Authorization to Construct (ATC) permit from Construction Grants and Loans, and
3. prior to discharge from said PRF, apply to the Division and receive an Authorization to Operate
(ATO) new wastewater treatment components, and
4. discharge from said treatment works and plastics recycling facility via Outfall 002 (located on the
attached map) into the Cape Fear River, a Class C waterbody within the Cape Fear River Basin.

DAK Americas, LLC
Cedar Creek Site
Receiving Stream: Cape Fear River Stream Class: C
Drainage Basin: Cape Fear River $asin Sub -Basin: 03-06-15
Latitude: 34° 58' 42" N Longitude: 78° 47' 02" W
State Grid/Quad: H 23 NE / Cedar Creek, NC
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North
Facility
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NPDES Permit NC0003719
Cumberland County

Permit NC0003719
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge from Outfall 002. Such discharges shall be limited and monitored by the Permittee as
suecified below:
Effluent
Characteristics
Limits
• Monitoring
• Requirements
.
:Monthly_
Average
Daily .
Maximum
Measurement .
Frequency
; Sample ,..
: ° Type
,* Sample
Location I
Flow
0.500 MGD
Continuous
Recording
I or E
Total Suspended Solids (TSS)
76 lbs /day
247 lbs/day
1/Week
Composite 2
E
BOD5, 20°C (April 1— October 31)
46 lbs /day
122 lbs /day
1/Week
Composite 2
E
BOD5, 20°C (November 1— March 31)
92 lbs /day
244 lbs /day
1/Week
Composite 2
E
NH3 N (April 1-October 31)
13 lbs /day
26 lbs /day
1/Week
Composite 2
E
NH3-N (November 1— March 31)
26 lbs /day
52 lbs /day
1/Week
Composite 2
E
Fecal Coliform (geometric mean)
1/Week
Grab
E
Total Residual Chlorine 3
28 µg/L .
1/Week
Grab
E
Temperature (°C)
1/Week
Grab
E
Dissolved Oxygen 4
1/Week
Grab
E
pH
Not <6.0 nor > 9.0 standard units
1/Week
Grab
E
Total Nitrogen (NO2 + NO3 + TKN)
1/Quarter
Composite 2
E
Total Phosphorus
1/Quarter
Composite 2
E
Acute Toxicity 5
1/Quarter
Composite 2
E
Dissolved Oxygen 6
1/Week
Grab
U & D
Temperature (°C) 6
1/Week
Grab
U & D
Conductivity 6
1/Week
Grab
U & D
Footnotes:
1 E = Effluent; I = Influent; U = upstream 2 mi. from Outfall. D = downstream, 100 yards upstream of Lock and Dam #3.
2 Composite samples must be refrigerated.
3 Total Residual Chlorine (TRC) - the Permittee shall continue to report all values recorded using North Carolina -
certified field and lab test methods. However, because low-level TRC is difficult to quantify in a wastewater matrix,
the Division shall consider all effluent values reported below 50 µg/L to be compliant.
4 Effluent dissolved oxygen (DO) shall not fall below 5 mg/L. The Permittee shall collect effluent DO samples from the
box combining effluents of Outfalls 001 and 002.
5 Whole Effluent Toxicity (WET) testing; acute toxicity P/F at 90% using Fathead Minnow. WET tests shall be
conducted in February, May, August and November [See Part A. (2.)]. The Permittee shall collect toxicity samples
from the box combining effluents of Outfalls 001 and 002.
6 Receiving Stream Monitoring — As a member of the Middle Cape Fear River Basin Association, the Permittee's
instream monitoring responsibilities are hereby waived by Memorandum of Agreement. However, should this
membership terminate for any reason, the Permittee shall notify the Division immediately, and the Permittee shall
immediately resume instream monitoring requirements, as specified herein.
The Permittee shall add no chromium, zinc, or copper to the treatment system except as pre -approved
additives to biocide compounds or those resulting from the normal degradation of process piping or equipment.
The Permittee shall discharge no floating solids or foam visible in other than trace amounts.
•
Additional effluent limitations, monitoring requirements, and special conditions apply to this permit
[see tables, Part A. (1.), continued, and Special Conditions A. (2.) through A. (5.)].

Permit NC0003719
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Continued)
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from Outfall 002. Such discharges shall be limited and monitored by the Permittee for
OCPSF parameters, as specified below:
Effluent
Characteristics ..
., h
Limits
Monitoring
'. Requirements
DAILY is
, MONTHLY.'
AVERAGE..
y)
(pounds/day):
M easurement.
Frequency ';
Sample
Type.:;
- Sample i
Location.
r
mAximum,
ounds/da
(pounds/day)
Acenaphthene
0.112
0.042
1/Year
Grab
Effluent
Acenaphthylene
0.112
0.042
1/Year
Grab
Effluent
Acrylonitrile
0.460
0.183
1/Year
Grab
Effluent
Anthracene
0.112
0.042
1/Year
Grab
Effluent
Benzene
0.259
0.070
1/Year
Grab
Effluent
Benzo(a)anthracene
0.112
0.042
1/Year
Grab
Effluent
3,4-Benzofluoranthene
0.116
0.044 _
1/Year
Grab
Effluent
Benzo(k)fluoranthene
0.112
0.042
1/Year
Grab
Effluent
Benzo(a)pyrene
0.116
0.044
1/Year
Grab
Effluent
Bis(2-ethylhexyl) phthalate
0.531
0.196
1/Year
Grab
Effluent
Carbon Tetrachloride
0.072
0.034
1/Year
Grab
Effluent
Chlorobenzene
0.053
0.029
1/Year
Grab
Effluent
Chloroethane
0.510
0.198
1/Year
Grab
Effluent
Chloroform
0.087
0.040
1/Year
Grab
Effluent
2-Chlorophenol
0.186
0.059
1/Year
Grab
Effluent
Chrysene
0.112
0.042
1/Year
Grab
Effluent
Di-n-butyl phthalate
0.108
0.051
1/Year
Grab
Effluent
1,2-Dichlorobenzene
0.310
0.146
1/Year
Grab
Effluent
1,3-Dichlorobenzene
0.084
0.059
1/Year
Grab
Effluent
1,4-Dichlorobenzene
0.053
0.029
1/Year
Grab
Effluent
1,1-Dichloroethane
0.112
0.042
1/Year
Grab
Effluent
1,2-Dichloroethane
0.401
0.129
1/Year
Grab •
Effluent
1,1-Dichloroethylene
0.048
0.030
1/Year
Grab
Effluent
1,2-trans-Dichloroethylene
0.103
0.040
1/Year
Grab
Effluent
2,4-Dichlorophenol
0.213
0.074
1/Year
Grab
Effluent
1,2-Dichloropropane
0.437
0.291
1/Year
Grab
Effluent
1,3-Dichloropropylene
0.084
0.055
1/Year
Grab
Effluent
Diethyl phthalate
0.386
0.154
1/Year
Grab
Effluent
2,4-Dimnethylphenol
0.068
0.034
1/Year
Grab
Effluent
Dimethyl phthalate
0.089
0.036
1/Year
Grab
Effluent
4,6-Dinitro-o-cresol
0.527
0.148
1/Year
Grab
Effluent
2,4-Dinitrophenol
0.234
0.135
1/Year
Grab
Effluent
2,4-Dinitrotoluene
0.542
0.215
1/Year
Grab
Effluent
Ethylbenzene
0.205
0.061
1/Year
Grab
Effluent
Fluoranthene
0.129
0.048
1/Year
Grab
_ Effluent
Fluorene
0.112
0.042
1/Year
Grab
Effluent
[Part A. (1.) continues on next page]

Permit NC0003719
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(OCPSF - Continued)
• Effluent, . _,°
. ,* < ,.
Characteristics-'•.
.'
r y Limits. °,; �' °'
; . . , t . ...'
.
° Monitoring Requirements �,
<<: . - - j : -
•i
5 i � , .; `_
r ;:y�. _� x
' .
. DAILY ;
(pounds/day)
MONTHLY
AVERAGE.
(Pounds/day)
, .. :.
Measurement -
. Frequency , 1
..
Sample
Sample's
Type
,
Sample
Location
Hexachlorobenzene 1
1.6 µg/L
0.03 µg/L
1/Year
Grab
Effluent
Hexachlorobutadiene
0.093
0.038
1/Year
Grab
Effluent
Hexachloroethane
0.103
0.040
1/Year
Grab
Effluent
Methyl Chloride
0.361
0.164
1/Year
Grab
Effluent
Methylene Chloride
0.169
0.076
1/Year
Grab
Effluent
Naphthalene
0.112
0.042
1/Year
Grab
Effluent
Nitrobenzene
0.129
0.051
1/Year
Grab
Effluent
2-Nitrophenol
0.131
0.078
1/Year
Grab
Effluent
4-Nitrophenol
0.236
0.137
1/Year
Grab
Effluent
2,6-Dinitrotoluenet
49.0 µg/L
0.48 µg/L
1/Year
Grab
Effluent
Phenanthrene
0.112
0.042
1/Year
Grab
Effluent
Phenol
0.049
0.029
1/Year
Grab
Effluent
Pyrene
0.127
0.048
1/Year
Grab
Effluent
Tetrachloroethylene
0.106
0.042
1/Year
Grab
Effluent
Toluene
0.152
0.049
1/Year
Grab
Effluent
1,2,4-Trichlorobenzene
0.266
0.129
1/Year
Grab -
Effluent
1,1,1-Trichloroethane
0.103
0.040
1/Year
Grab
Effluent
1,1,2-Trichloroethane
0.103
0.040
1/Year
Grab
Effluent
Trichloroethylene
0.103
0.040
1/Year
Grab
Effluent
Vinyl Chloride
0.510
0.198
1/Year
Grab
Effluent
Metals and Toxicants
Total Chromium
5.3
2.1
1/Year
Grab
Effluent
Total Copper
6.4
2.8
1/Year
Grab
Effluent
Cyanide
2.3
0.8
1/Year
Grab
Effluent
Total Lead
1.3
0.6
1/Year
Grab
Effluent
Total Nickel
7.6
3.2
1/Year
Grab
Effluent
Total Zinc
5.0
2.0
1/Year
Grab
Effluent
1. Water -quality based limit.

Permit NC0003719, '
SPECIAL CONDITIONS AND MONITORING REQUIREMENTS
A. (2.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The Permittee shall conduct acute toxicity tests 1/Quarter using protocols defined in the North Carolina
Procedure Document entitled "Pass/Fail Methodology for Determining Acute Toxicity in a Single Effluent
Concentration" (Revised July, 1992 or subsequent versions). The monitoring shall be performed as a Fathead
Minnow (Pimephales promelas) 24-hour static test. The effluent concentration, at which there may be at no time
significant acute mortality, is 90% (defined as treatment two in the procedure document). Effluent samples for
self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment.
The tests will be performed during the months of February, May, August, and November.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE6C.
Additionally, DWQ Form AT-2 (original) is to be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the 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 (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
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.

S
Permit NC0003719
SPECIAL CONDITIONS AND MONITORING REQUIREMENTS
A. (3.) BIOCIDE APPROVAL
The Permittee shall obtain approval from the Division's Aquatic Toxicology Unit prior to discharging any
biocide (not previously approved by the Division) under this permit. Approval for use of any biocide not
previously The Permittee shall request approval of any new unauthorized biocide at least 90 days in advance of
planned usage.
Contact the Aquatic Toxicology Unit for detailed instructions on requesting biocide approval:
NC DENR / DWQ / Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Concentrations of chromium, copper, or zinc added to biocides shall not exceed applicable water quality
standards or action levels in the receiving stream.
A. (4.) LABORATORY TEST -METHOD QUANTITATION LEVELS AND COMPLIANCE
For any given parameter, the Permittee must apply a state -certified analytical test method with a practical
quantitation level (PQL) at or below the NPDES permit limit. If such level of analytical sensitivity is not
technologically feasible, the Permittee shall employ a state -certified analytical method with the lowest available
test -method PQL, and values reported as "not detected" by this lowest available PQL shall be deemed
"compliant" with this permit.
A. (5.) PLASTICS RECYCLING FACILITY (PRF) - WASTE CHARACTERIZATION
Although plastics recycling facility (PRF) construction does not require an NPDES Authorization to
Construct (ATC) Permit, an ATC permit is required for any additional treatment units or processes
necessary to treat PRF wastes.
Therefore, during construction of the proposed PRF (flow estimated at 0.111 MGD), DAK shall locate
and designate internal PRF Outfall 001, a sampling location influent to the onsite WWTP, whereby the
Permittee may sample and analyze PRF wastes prior to mixing with other wastes. No later than 90 days
prior to receiving PRF wastes at the onsite WWTP, DAK shall provide a written report, anticipating the
character of PRF wastes generated under SIC 5162, and specifically identify:
1. waste chemical character and methods used to identify, quantify and characterize wastes
2. waste treatability by existing onsite WWTP processes
3. examples and character of wastestreams from similar active/operating SIC 5162 PRFs
4. any anticipated interference by PRF wastes with existing wastestream treatability
5. any new treatment units identified or processes requiring ATC
The Division reserves the right to reopen this permit to include additional treatment and/or monitoring
based on a satisfactory waste characterization.

Fact Sheet Addendum 2
for NPDES Development - Permit Final
August 27, 2009
DAK Americas LLC — Cedar Cr
NC0003719
Joe R. Corporon, L.G.
NPDES Program
DAK reviewed the it DRAFT — AL and provided comments to DWQ (received August 18,
2009). The Divisi n .11 revise the ermit FINAL according to the following:
1. DAK requests that DWQ correct the permit Supplement to Cover Sheet by revising the list of
treatment -system components, and has provided corrections. DWQ has no objections.
2. Considering the FINAL permitted flow of 0.500 MGD, DAK requests that DWQ reclassify
the WWTP from a Grade III to a Grade II, and thereby decrease the monitoring frequencies
from 3/Week to the appropriate 1/Week. DWQ has no objections. Likewise, receiving -stream
monitoring will be conducted 1/Week, with no variation in winter.
3. OCPSF Monitoring. DWQ has previously relaxed most OCPSF monitoring frequencies from
1/Quarter to the current 1/Year based on minimal detection. For renewal based on this
analytical record, DAK requests that DWQ allow DAK to discontinue monitoring of all
OCPSF-listed parameters. DAK sites state regulations granting the Director discretionary
authority to honor this request. However, the Division does not agree that "no monitoring"
serves to adequately govern the receiving -stream environment. DWQ therefore must deny
DAK's request. However, based on the analytical record, DWQ will relax the monitoring
frequency of water -quality based parameters [2, 6-Dinitrotoluene (code 34626) and
Hexachlorobenzene (code 39700)] and metals from 1/Quarter to 1/Year consistent with the
other OCPSF parameters in this permit [see permit Section A.(1.)].
4. DAK requests that DWQ modify permit limits for ammonia (NH3 as N), reinstating 35 & 70
lbs/day (summer); 70 & 140 lbs/day (winter), Monthly Average & Daily Maximum,
respectively, from the previous permit (Phase II at 0.500 MGD). These previous permit limits
are in error and were not adjusted in proportion to flow. The Division has corrected these errors
for the DRAFT FINAL to 13 & 26 lbs/day (summer); 26 & 521bs/day (winter) consistent with
flow -proportional BOD/NH3 limits since 1989 based on modeling considering receiving -stream
capacity. No changes recommended (see Fact Sheet Addendum 1). Based on data from 2005
through 2008, DAK has not exceeded these new NH3 limits and should have no problem with
future permit limit compliance.

August 17, 2009
Mr. Joe R. Corporon, L.G.
NPDES Program, East
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27604
Subject: Issuance of NPDES Permit No. NC0003719
DAK Americas LLC - Cedar Creek Site
3468 Cedar Creek Road
Fayetteville, NC 28301
Cumberland County
Dear Mr. Corporon:
Thank you for sending me a copy of the draft final permit for DAK Americas Cedar
Creek site. Overall DAK is very pleased with the draft final permit. Upon review, how-
ever, we do have a few additional comments.
1. Flow and Facility Grade
DAK requested, and DWQ agreed, that the permitted flow would remain at 0.500
MGD as in the existing permit. However, the cover letter to the permit states that the
wastewater treatment system is a Grade III facility with monitoring frequencies of
3/week. In reviewing 15A NCAC 08G .0302 (b) it defines a Grade II facility as:
Systems that utilize an activated sludge or fixed growth process with a permitted
flow less than or equal to 0.5 million gallons per day (mgd) are assigned the clas-
sification of Grade II Biological Water Pollution Control System.
In reviewing 15A NCAC 02B .0508 (d) it requires monitoring frequencies of 1/week
for Grade II facilities.
DAK requests that the Grade of the wastewater treatment system be established as a
Grade II facility and that the monitoring frequency be 1/week. This is consistent with
a 0.500 MGD facility as defined by the regulations. Increasing the monitoring fre-
quency from 1/week to 3/week will add over $100,000 per year in analytical testing
cost.

2. OCPSF Related Parameters
On page 2 of the cover letter to the permit and in Section A.(1.) of the permit, nu-
merical limits and monitoring frequencies for 2,6-Dinitrotoluene and Hexachloroben-
zene are established.
The requirement for Hexachlorobenzene was dropped from the existing permit when
the effluent flow limit decreased from 1.25 MGD to 0.500 MGD. This was, to my
understanding, because the analytical results showed that it was below the level of
quantification. These parameters were in the permit when the facility was previously
operated by Monsanto. Since the Monsanto operation ceased, these parameters are no
longer in the effluent.
DAK requests that the permit limits and quarterly monitoring requirements for 2,6-
Dinitrotoluene and Hexachlorobenzene be removed from the permit. DAK also re-
quests that the monitoring for all of the OCPSF parameters specified in the table
shown on pages 4-5 of the permit be waived based on 40 CFR 122.44(a)(2)(i). See
attached analytical results that provide the basis for this request. These results show
that these parameters have been below the level of quantification since 2002.
3. Total Residual Chlorine (TRC)
A TRC limit has been added to the permit of 28 ug/L. However, compliance is re-
quired only if chlorine is used.
The Cedar Creek site does not add chlorine to the effluent from the wastewater treat-
ment plant. Therefore DAK requests that the TRC limit and monitoring requirement
be deleted from the permit or triggered only if DAK begins use of chlorine. If this is
not possible, DAK requests a six month period from the effective date of the permit to
allow the facility to obtain the new low level chlorine testing equipment, train staff,
and obtain laboratory certification for this parameter.
4. WWTP Equipment
On the SUPPLEMENT TO PERMIT COVER SHEET it states that
DAK Americas LLC is hereby authorized to continue to operate an existing 0.300
MGD wastewater treatment plant consisting of flow equalization, spill basin, pH
adjustment, oil skimming, comminutor, dual aeration basins, clarifier, parshall
flume, sludge pump station, dual aerobic digesters, aerated biosolids holding ba-
sin, and biosolids drying beds and associated equipment.
DWQ granted DAK's request to maintain the permitted flow of 0.500 MGD. DAK
requests the flow in this paragraph be changed to reflect the agreed upon 0.500 MGD.
The comminutor was removed from service years ago and one of the aerobic digest-
ers has not been operational since prior to 2002. DAK requests that these units,
which were not listed in the application, be removed from the permit language. DAK
suggests that the permit language be changed to read:

DAK Americas LLC is hereby authorized to continue to operate an existing 0.500
MGD wastewater treatment plant consisting of flow equalization, spill basin, pH
adjustment, oil skimming, dual aeration basins, clarifier, parshall flume, sludge
pump station, an aerobic digester, aerated biosolids holding basin, and biosolids
drying beds and associated equipment.
5. Ammonia Nitrogen
The Fact Sheet Addendum states that the previous limit for ammonia nitrogen was 23
lb/day and that the flow was 0.859 MGD.
These numbers are incorrect. The existing permit has an ammonia nitrogen limit of
35 lbs/day and a permitted flow of 0.500 MGD. DAK requests that the ammonia ni-
trogen limit remain at 35.O lb/day for the summer limit and 70.O lb/day for the winter
limit.
DAK looks forward to working with the Division to renew the site's NPDES permit. If
you have questions, please call me at [phone].
Sincerely,
Elizabeth Wike
Environmental Engineer
Water Quality Management
Attachments
Regulatory references cited above
15A NCAC 08G .0302 (b)
15A NCAC 02B .0508 (d)
40 CFR 122.44(a)(2)(i)
OCPSF data

15A NCAC 08G .0302 CLASSIFICATION OF BIOLOGICAL WATER POLLU-
TION CONTROL TREATMENT SYSTEMS
(a) The following discharging systems are assigned a classification of Grade I Biological
Water Pollution Control System unless the permitted flow, or operational complexity of
the system requires a higher classification:
(1) septic tank/sand filter systems;
(2) biological lagoon systems; and
(3) constructed wetlands and associated appurtenances.
(b) Systems that utilize an abtivatedsludge or.- fixed;growth pirocess:with a permittedflow
less than or equal to 0.5 million gallons per ,day°(mgd).,.are assigned the classification- of
Grade II Biological Water Pollution Control'System:
(c) Systems utilizing an activated sludge or fixed growth process with permitted flows of
greater than 0.5 through 2.5 million gallons per day (mgd) are assigned the classification
of Grade III Biological Water Pollution Control System.
(d) Systems utilizing an activated sludge or fixed growth process with a permitted flow
greater than 2.5 million gallons per day (mgd) are assigned a classification of Grade IV
Biological Water Pollution Control System.
(e) Any system receiving a classification of Grade II Biological Water Pollution Control
System that is required to achieve nutrient reduction is assigned the classification of
Grade III Biological Water Pollution Control System.
(f) Any system receiving a classification of Grade III Biological Water Pollution Control
System that is required to achieve nutrient reduction is assigned the classification of
Grade IV Biological Water Pollution Control System.
History Note: Authority G.S. 90A-37; Eff. April 1, 1999; Amended Eff. December 1,
2006.

15A NCAC 02B .0508 TESTS AND MEASUREMENTS APPLICABLE TO SICS.
(a) Determination of Type and Frequency of Tests and Measurements:
(1) Introduction. The .tables set forth in this Rule are designed to indicate, for any par-
ticular water pollution control facility or point source, the minimum standard tests
and measurements which are to be performed, the minimum frequency with which
the tests and measurements are to be conducted, and the location and minimum num-
ber of sampling points that are required.
(2) Determination of Facility Class and SIC Numbers. Before these tables may be ap-
plied, the standard industrial classification(s) of the activities discharging to the water
pollution control facility must be determined from The Standard Industrial Classifica-
tion Manual. The classification of the facility as determined by the Water Pollution
Control System Operators Certification Commission, must also be known.
(b) Modification of Test(s) or Measurement(s) Requirements:
(1) If it is demonstrated to the satisfaction of the Director that any of the tests and
measurements, sampling points, or frequency of sampling requirements, as required
in this Rule for a particular SIC group, are not applicable to the discharge of a par-
ticular water pollution control facility, or if it can be demonstrated that the objectives
of this Section can be achieved by other acceptable means, then such requirements
may be waived or modified to the extent that the Director determines to be appropri-
ate.
(2) In addition to the tests and measurements as listed in this Rule applicable to each
of the SIC groups, persons subject to this Section may be required to perform such
additional tests and measurements at such sampling points and with such frequency as
are determined by the Director to be necessary to adequately monitor constituents of
the waste discharge and their effect upon the receiving waters. This monitoring may
include, but not be limited to weekends and holidays as deemed necessary by the Di-
rector to ensure representative sampling and proper operation and maintenance of any
facility.
(c) Unclassified Activities:
(1) Any person owning or operating a water pollution control facility who determines
that a major SIC group(s) is not listed in this Rule for an activity subject to this Sec-
tion shall so notify the Division.
(2) The Director shall prescribe the number and location of sampling points and the
frequency with which tests and measurements must be made for such pollutant or pol-
lutant effects as it shall deem necessary to properly monitor the quantity or quality of
waste discharges resulting from any activity subject to this Section which is not in-
cluded in the major SIC groups set forth in this Rule and to properly monitor effects
of the discharges upon the waters of this state.

(d) Index of Major Standard Industrial Groups:
SIC Number Major Products or Services
1400-1499 Mining
2000-2199 Food, Beverage and Tobacco Processing
2200-2299 Textile Processing
2400-2599 Lumber and Wood Products Except Wet Decking
2600-2699 Paper and Allied Products
2800-2899 Chemical and Allied Products
2900-2999 Petroleum Refining and Related Industries
3100-3199 Leather and Leather Products
3400-3699 Fabricated Metal Products Except Ordnance, Machinery and
Transportation Equipment Machinery Electrical Machinery,
Equipment and Supplies
4900-4939 Electric, and Gas Services
4941 Water Supply
4952 Wastewater and all facilities discharging primarily domestic
wastewater
7000-8999 Services
Abbreviations for sampling locations and frequencies to be used with SIC monitoring re-
quirements:
"I" means influent "E" means effluent "U" means upstream "D" means downstream
"2/month" means samples are collected twice per month with a required 10-day interval
between the collection of the samples
"3/week" means samplesare collected three times per week on three separate days
CHEMICAL AND ALLIED PRODUCTS
MINIMUM REQUIREMENTS FOR SIC 2800-2899
EFFLUENT LIMITED
REQUIRED TEST
LOCATION FREQUENCY
CLASS I CLASS II CLASS III CLASS IV
1. pH E Weekly Weekly 3/week Daily
2. Temperature, °C E Weekly Weekly 3/week Daily
3. BOD, 5-day, 20°C E 2/month Weekly 3/week Daily
4. TSS E 2/month Weekly 3/week Daily
5. Total Nitrogen E * * * *
6. Total Phosphorus E * * * *
7. Toxics and Toxicity ** ** ** **

WATER QUALITY LIMITED
1. Dissolved Oxygen E Weekly Weekly 3/week Daily
2. Dissolved Oxygen U,D Weekly Weedy 3/week+ 3/week+
3. pH E Weekly eeM 3/week Daily
4. Temperature, °C E Weekly Weekly 3/week Daily
5. Temperature, °C U,D Weekly Weekly 3/week+ 3/week+
6. BOD, 5-day, 20°C E 2/month Weekly 3/week Daily
7. TSS E 2/month eek1 ; 3/week Daily
8. Total Nitrogen E * * * *
9. Total Phosphorus E * * * *
10. Toxics and Toxicity ** ** ** **
11. Conductivity E Weekly Weekly 3/week Daily
12. Conductivity U,D Weekly Weekly 3/week+ 3/week+

40 CFR 122.44(a)(2)(i)
§122.44 Establishing limitations, standards, and other permit conditions (applicable
to State NPDES programs, see §123.25)
In addition to the conditions established under §122.43(a), each NPDES permit shall in-
clude conditions meeting the following requirements when applicable.
(a)
(2) Monitoring waivers for certain guideline -listed pollutants.
(i) The Director may authorize a discharger subject to technology -based effluent limi-
tations guidelines and standards in an NPDES permit to forego sampling of a pollut-
ant found at 40 CFR Subchapter N of this chapter if the discharger has demonstrated
through sampling and other technical factors that the pollutant is not present in the
discharge or is present only at background levels from intake water and without any
increase in the pollutant due to activities of the'discharger.

OCPSF Related Parameters
Permit No. NC 0003719
PARAi<1ETERNA11E
2001
February
flay
August
Novembel
Acenaphthene
ND
<1.0 ppb
<10.0 ppb
<10.0 ppb
<9.4ppb
Acenaphthylene
ND
<1.0 ppb
<0.95 ppb
<10.0 ppb
<9.4ppb
Acrylonitrile
ND
<100.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
Anthracene
ND
<1.0 ppb
<0.95 ppb
<10.0 ppb
<9.4ppb
Benzene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Benzo(a)anthracene
ND
<1.0 ppb
<1.0 ppb
<1.2 ppb
<1.0 ppb
3,4-Benzofluranthene
ND
<1.0 ppb
<1.0 ppb
<1.2 ppb
<1.0 ppb
Benzo(k)fluoranthene
ND
<1.0 ppb
<1.0 ppb
<1.2 ppb
<1.0 ppb
Benzo(a)pyrene
ND
<0.2 ppb
<0.2 ppb
<0.24 ppb
<0.20 ppb
Bis(2-ethylhexyl) phthalate
PRESENT
<10.0 ppb
23.0 ppb
<10.0 ppb
<9.4ppb
Carbon Tetrachloride
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Chlorobenzene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Chloroethane
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
Chloroform
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
2-Chlorophenol
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.5 ppb
Chrysene
ND
<1.0 ppb
<1.0 ppb
<1.2 ppb
<1.0 ppb
Di-n-butyl phathalate
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<9.4 ppb
1,2-Dichlorobenzene
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
1,3-Dichlorobenzene
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
1,4-Dichlorobenzene
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
1,1-Dichloroethane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,2-Dichloroethane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,1-Dichloroethylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,2-trans-Dichloroethylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
2,4-Dichlorophenol
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.5 ppb
1,2-Dichloropropane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,3-Dichloropropylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Diethyl phthalate
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<9.4 ppb
2,4-Dimethylphenol
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.5 ppb
Dimethyl phthalate
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<9.4 ppb
4,6-Dinitro-o-cresol
ND
<51.0 ppb
<50.0 ppb
<50.0 ppb
<47.0 ppb
2,4-Dinitrophenol
ND
<51.0 ppb
<48.0 ppb
<47.0 ppb
<48.0 ppb
2,4-Dinitrotoluene
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.5 ppb
2,6-Dinitrotoluene
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.4 ppb
Ethylbenzene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Fluoranthene
ND
<1.0 ppb
<0.95 ppb
<10.0 ppb
<9.4 ppb
Fluorene
ND
<1.0 ppb
<0.95 ppb
<10.0 ppb
<9.4 ppb
Hexachlorobenzene
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<9.4 ppb
Hexachlorobutadiene
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<9.4 ppb
Hexachloroethane
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.5 ppb
Methyl Chloride
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
Methylene Chloride
ND
<10.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Naphthalene
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.5 ppb
Nitrobenzene
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.5 ppb
2-Nitrophenol
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.4 ppb

Permit No. NC 0003719
, PARAMETER NAME
2001
February
May
August
Novembetit
4-Nitrophenol
ND
<51.0 ppb
<48.0 ppb
<47.0 ppb
<48.0 ppb
Phenanthrene
ND
<1.0 ppb
<0.95 ppb
<10.0 ppb
<9.4 ppb
Phenol
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb .
<9.5 ppb
Pyrene
ND
<1.0 ppb
<0.95 ppb
<10.0 ppb
<9.4 ppb
Tetrachloroethylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Toluene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Total Chromium
PRESENT
6.9 ppb
8.7 ppb
16.0 ppb
11.0 ppb
Total Copper
PRESENT
6.0 ppb
8.9 ppb
26.0 pph
16.0 ppb
Total Cyanide
PRESENT
<5.0 ppb
6.0 ppb
14.0 ppb
<.5.0 ppb
Total Lead
PRESENT
3.0 ppb
2.3 ppb
2.9 ppb
6.4 ppb
Total Nickel
PRESENT
6.0 ppb
8.0 ppb
68.0 ppb
38 0 ppb
Total Zinc
PRESENT
910ppb
180.0 ppb
320.0 ppb
180.0 ppb
1,2,4-Trichlorobenzene
ND
<10.0 ppb
<9.6 ppb
<9.4 ppb
<9.5 ppb
1,1,1-Trichloroethane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,1,2-Trichloroethane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Trichloroethylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Vinyl Chloride
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb

OCPSF Related Parameters
Permit No. NC 0003719
PARAMETER NAME
2002
February
May
August
Novembell
Acenaphthene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Acenaphthylene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Acrylonitrile
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<100.0 ppb
Anthracene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Benzene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Benzo(a)anthracene
ND
<0.1 ppb
<1.1 ppb
<.1 ppb
<.1 ppb
3,4-Benzofluranthene
ND
<0.1 ppb
<0.1 ppb
<.1 ppb
<.1 ppb
Benzo(k)fluoranthene
ND
<0.1 ppb
<1.1 ppb
<.1 ppb
<.1 ppb
Benzo(a)pyrene
ND
<0.23 ppb
<0.22 ppb
<0.21 ppb
<0.20 ppb
Bis(2-ethylhexyl) phthalate
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Carbon Tetrachloride
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Chlorobenzene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Chloroethane
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
Chloroform
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
2-Chlorophenol
ND
<9.7 ppb •
<11.0 ppb
<11.0 ppb
<13.0 ppb
Chrysene
ND
<0.2 ppb
<1.1 ppb
<.2 ppb
<.2 ppb
Di-n-butyl phathalate
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
1,2-Dichlorobenzene
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
1,3-Dichlorobenzene
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
1,4-Dichlorobenzene
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
1,1-Dichloroethane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,2-Dichloroethane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,1-Dichloroethylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,2-trans-Dichloroethylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
2,4-Dichlorophenol
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
1,2-Dichloropropane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,3-Dichloropropylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Diethyl phthalate
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
2,4-Dimethylphenol
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
Dimethyl phthalate
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
4,6-Dinitro-o-cresol
ND
<51.0 ppb
<50.0 ppb
<55.0 ppb
<56.0 ppb
2,4-Dinitrophenol
ND
<49.0 ppb
<54.0 ppb
<53.0 ppb
<66.0 ppb
2,4-Dinitrotoluene
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
2,6-Dinitrotoluene
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
Ethylbenzene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Fluoranthene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Fluorene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Hexachlorobenzene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Hexachlorobutadiene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Hexachloroethane
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
Methyl Chloride
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
Methylene Chloride
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Naphthalene
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
Nitrobenzene
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
2-Nitrophenol
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb

Permit No. NC 0003719
PARAMETER NAME
2002
February
May
August
November
4-Nitrophenol
ND
<49.0 ppb
<54.0 ppb
<53.0 ppb
<66.0 ppb
Phenanthrene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Phenol
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
Pyrene
ND
<10.0 ppb
<10.0 ppb
<11.0 ppb
<11.0 ppb
Tetrachloroethylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Toluene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Total Chromium
PRESENT
13.0 ppb
<20.0 ppb
<10.0 ppb
<5.0 ppb
Total Copper
PRESENT
23.0 ppb
28.0 ppb
9.9 pith
32. ppb
Total Cyanide
PRESENT
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Total Lead
PRESENT
7.1 ppb
2.0 ppb
2.2 ppb
10.0 ppb
Total Nickel
PRESENT
18.0 ppb
<10.0 ppb
15.0 ppb
<10.0 ppb
Total Zinc
PRESENT
480.0 ppb .
110.0 ppb
270.0 ppb
,340.0 ppb
1,2,4-Trichlorobenzene
ND
<9.7 ppb
<11.0 ppb
<11.0 ppb
<13.0 ppb
1,1,1-Trichloroethane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
1,1,2-Trichloroethane
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Trichloroethylene
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Vinyl Chloride
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb

OCPSF Related Parameters
Permit No. NC 0003719
PARAMETER NAME
2003
February
May
August
November
Acenaphthene
ND
<4.8 ppb
Accnaphthylenc
ND
<2.4 ppb
Acrylonitrile
ND
<100.0 ppb
Anthracene
ND
<1.0 ppb
Benzene
ND
<5.0 ppb
Bcnzo(a)anthracene
ND
<0.1 ppb
3,4-Benzofluranthene
ND
<0.1 ppb
Benzo(k)fluoranthene
ND
<0.1 ppb
Benzo(a)pyrene
ND
<0.2 ppb
Bis(2-ethylhexyl) phthalate
ND
<9.7 ppb
Carbon Tetrachloride
ND
<5.0 ppb
Chlorobenzene
ND
<5.0 ppb
Chloroethane
ND
<10.0 ppb
Chloroform
ND
<5.0 ppb
2-Chlorophenol
ND
<9.7 ppb
Chryscnc
ND
<9.7 ppb
Di-n-butyl phathalatc
ND
<0.2 ppb
1,2-Dichlorobenzene
ND
<10.0 ppb
1,3-Dichlorobenzene
ND
<10.0 ppb
1,4-Dichlorobenzene
ND
<10.0 ppb
1,1-Dichloroethane
ND
<5.0 ppb
1,2-Dichloroethane
ND
<5.0 ppb
1,1-Dichloroethylenc
ND
<5.0 ppb
1,2-trans-Dichloroethylene
ND
<5.0 ppb
2,4-Dichlorophenol
ND
<9.7 ppb
1,2-Dichloropropane
ND
<5.0 ppb
1,3-Dichloropropylene
ND
<5.0 ppb
Diethyl phthalate
ND
<9.7 ppb
2,4-Dimethylphenol
ND
<9.7 ppb
Dimethyl phthalate
ND
<9.7 ppb
4,6-Dinitro-o-cresol
ND
<49.0 ppb
2,4-Dinitrophenol
ND
<49.0 ppb
2,4-Dinitrotoluene
ND
<9.7 ppb
2,6-Dinitrotoluene
ND
<9.7 ppb
Ethylbenzene
ND
<5.0 ppb
Fluoranthene
ND
<0.2 ppb
Fluorene
ND
<0.5 ppb
Hexachlorobenzene
ND
<9.7 ppb
Hexachlorobutadiene
ND
<9.7 ppb
Hexachloroethane
ND
<9.7 ppb
Methyl Chloride
ND
<10.0 ppb
Methylene Chloride
ND
<10.0 ppb
Naphthalene
ND
<2.4 ppb
Nitrobenzene
ND
<9.7 ppb
2-Nitrophenol
ND
<9.7 ppb

Permit No. NC 0003719
PA RAM ETERNAME
2003
February
Nlay
August
November
4-Nitrophenol
ND
<49.0 ppb
Phenanthrene
ND
<0.2 ppb
Phenol
ND
<9.7 ppb
Pyrene
ND
<0.5 ppb
Tetrachloroethylcne
ND
<5.0 ppb
Toluene
ND
<5.0 ppb
Total Chromium
ND
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Total Copper
PRESENT
5.8 ppb
3.9 ppb
<2.0 ppb
3.1,p: `
Total Cyanide
PRESENT
<5.0 ppb
<5.0 ppb
<5.0 ppb
<5.0 ppb
Total Lead
ND
<10.0 ppb
<10.0 ppb
<10.0 ppb
<10.0 ppb
Total Nickel
PRESENT
<5.0 ppb
<5.0 ppb
<5.0 ppb
20.0 ppb
Total Zinc
PRESENT
98.0 pph
31.0 ppb
15.0 ppb
17.0 ppb
1,2,4-Trichlorobenzene
ND
<9.7 ppb
,1,1-Trichloroethane
ND
<5.0 ppb
1,1,2-Trichloroethane
ND
<5.0 ppb
Trichloroethylene
ND
<5.0 ppb
Vinyl Chloride
ND
<10.0 ppb

OCPSF Related Parameters
Permit No. NC 0003719
PARAMETER NAME
2004
February
May
August
November
Acenaphthene
ND
<.010 mg/1
Acenaphthylene
ND
<.010 mg/1
Acrylonitrile
ND
<.010 mg/1
Anthracene
ND
<.010 mg/I
Benzene
ND
<.0010 mg/I
Benzo(a)anthracene
ND
<.010 mg/1
3,4-Benzofluranthene
ND
<.010 mg/1
Benzo(k)fluoranthene
ND
<.010 mg/I
Benzo(a)pyrene
ND
<.010 mg/1
Bis(2-ethylhexyl) phthalate
ND
<.010 mg/1
Carbon Tetrachloride
ND
<.0010 mg/1
Chlorobenzene
ND
<.0010 mg/I
Chloroethane
ND
<.0010 mg/1
Chloroform
ND
<.0050 mg/1
2-Chlorophenol
ND
<.010 mg/1
Chrysene
ND
<.010 mg/1
Di-n-butyl phathalate
ND
<.010 mg/1
1,2-Dichlorobenzene
ND
<.0010 mg/1
1,3-Dichlorobenzene
ND
<.0010 mg/1
1,4-Dichlorobenzene
ND
<.0010 mg/1
1,1-Dichloroethane
ND
<.0010 mg/1
1,2-Dichloroethane
ND
<.0010 mg/1
1,1-Dichloroethylene
ND
<.0010 mg/I
1,2-trans-Dichloroethylene
ND
<.0010 mg/1
2,4-Dichlorophenol
ND
<.010 mg/1
1,2-Dichloropropane
ND
<.0010 mg/1
1,3-Dichloropropylene
ND
<.0010 mg/1
Diethyl phthalate
ND
<.010 mg/1
2,4-Dimethylphenol
ND
<.010 mg/1
Dimethyl phthalate
ND
<.010 mg/I
4,6-Dinitro-o-cresol
ND
<.010 mg/1
2,4-Dinitrophenol
ND
<.010 mg/1
2,4-Dinitrotoluene
ND
<.010 mg/1
2,6-Dinitrotoluene
ND
<.010 mg/1
Ethylbenzene
ND
<.0010 mg/1
Fluoranthene
ND
<.010 mg/1
Fluorene
ND
<.010 mg/1
Hexachlorobenzene
ND
<.010 mg/1
Hexachlorobutadiene
ND
<.010 mg/1
Hexachloroethane
ND
<.010 mg/1
Methyl Chloride
ND
<.0010 mg/l
Methylene Chloride
ND
<.0050 mg/1
Naphthalene
ND
<.0050 mg/I
Nitrobenzene
ND
<.010 mg/1
2-Nitrophenol
ND
<.010 mg/1

Permit No. NC 0003719
PARANIETER NAME
2004
February
May
August
November
4-Nitrophenol
ND
<.010 mg/1
Phenanthrene
ND
<.010 mg/1
Phenol
ND
<.010 mg/1
Pyrene
ND
<.010 mg/1
Tetrachloroethylene
ND
<.0010 mg/1
Toluene
ND
<.0050 mg/1
Total Chromium
ND
=_2.(1 ppb
<0.005 mg/I
<.0050 mg/1
<.0050 mg/1
Total Copper
PRESENT
rek5.0 pp!,
<0.003 mg/1
ii'r , ;
<.0030 mg/1
Total Cyanide
ND
<2.0 ppb
<0.005 mg/I
<0.005 mg/1
<0.005 mg/1
Total Lead
ND
<5.0 ppb
<0.003 mg/I
<0.003 mg/1
<0.003 mg/1
Total Nickel
PRESENT
50.0 ppb
0.005 mg/1
(1.007 mail
<0.005 mg/1
Total Zinc
PRESENT
180.0 ppb
0.009 m2/1
0.006 mg/1
0.010 mg/I
1,2,4-Trichlorobenzenc
ND
<.010 mg/1
1,1,1-Trichloroethane
ND
<.0010 mg/I
1,1,2-Trichloroethane
ND
<.0010 mg/1
Trichloroethylene
ND
<.0010 mg/1
Vinyl Chloride
ND
<.0010 mgll

OCPSF Related Parameters
Permit No. NC 0003719
IIIEARAMETER NAME
2005
February
May
August
November
Acenaphthene
ND
<.010 mg/1
Acenaphthylene
ND
<.010 mg/1
Acrylonitrile
ND
<.050 mg/1
Anthracene
ND
<.010 mg/I
Benzene
ND
<.0010 mg/I
Benzo(a)anthracene
ND
<.010 mg/1
3,4-Benzofluranthene
ND
<.010 mg/1
Benzo(k)fluoranthene
ND
<.010 mg/1
Benzo(a)pyrene
ND
<.010 mg/1
Bis(2-ethylhexyl) phthalate
ND
<.010 mg/1
Carbon Tetrachloride
ND
<.0010 mg/1
Chlorobenzene
ND
<.0010 mg/1
Chloroethane
ND
<.0010 mg/1
Chloroform
ND
<.0050 mg/1
2-Chlorophenol
ND
<.010 mg/1
Chrysene
ND
<.010 mg/1
Di-n-butyl phathalate
ND
<.010 mg/1
1,2-Dichlorobenzene
ND
<.0010 mg/1
1,3-Dichlorobenzene
ND
<.0010 mg/1
1,4-Dichlorobenzene
ND
<.0010 mg/1
1,1-Dichloroethane
ND
<.0010 mg/I
1,2-Dichloroethane
ND
<.0010 mg/1
1,1-Dichloroethylene
ND
<.0010 mg/1
1,2-trans-Dichloroethylene
ND
<.0010 mg/1
2,4-Dichlorophenol
ND
<.010 mg/1
1,2-Dichloropropane
ND
<.0010 mg/1
1,3-Dichloropropylene
ND
<.0010 mg/1
Diethyl phthalate
ND
<.010 mg/I
2,4-Dimethylphenol
ND
<.010 mg/1
Dimethyl phthalate
ND
<.010 mg/1
4,6-Dinitro-o-cresol
ND
<.010 mg/I
2,4-Dinitrophenol
ND
<.010 mg/1
2,4-Dinitrotoluene
ND
<.010 mg/1
2,6-Dinitrotoluene
ND
<.010 mg/I
Ethylbenzene
ND
<.0010 mg/1
Fluoranthene
ND
<.010 mg/1
Fluorene
ND
<.010 mg/1
Hexachlorobenzene
ND
<.010 mg/1
Hexachlorobutadiene
ND
<.010 mg/1
Hexachloroethane
ND
<.010 mg/1
Methyl Chloride
ND
<.0010 mg/1
Methylene Chloride
ND
<.0050 mg/1
Naphthalene
ND
<.0050 mg/1
Nitrobenzene
ND
<.010 mg/1
2-Nitrophenol
ND
<010 mg/I

Permit No. NC 0003719
PARAMETER NAME
2005
February
May
August
November
4-Nitrophenol
ND
<.010 mg/1
Phenanthrene
ND
<.010 mg/1
Phenol
ND
<.010 mg/I
Pyrene
ND
<.010 mg/1
Tetrachloroethylene
ND
<.0010 mg/1
Toluene
ND
<.0050 mg/I
Total Chromium
ND
<.0050 mg/I
<.0050 mg/1
<.0050 mg/1
<.005 mg/1
Total Copper
PRESENT
<0.003 mg/1
<0.003 mg/1
<.003 mg/1
Total Cyanide
ND
<0.005 mg/I
<0.005 mg/1
<0.005 mg/1
<.005 mg/1
Total Lead
ND
<0.003 mg/1
<0.003 mg/1
<0.003 mg/1
<.003mg/l
Total Nickel
PRESENT
<0.005 mg/1
<0.005 mg/1
<0.005 mg/1
.006 mg/I
Total Zinc
PRESENT
0.0, =• n,• I
0.010 mg/1
0.022 mg/1
.026 mg/I
1,2,4-Trichlorobenzene
ND
<.0010 mg/1
1,I,1-Trichloroethane
ND
<.0010 mg/1
1,1,2-Trichloroethane
ND
<.0010 mg/I
Trichloroethylerie
ND
<.0010 mg/1
Vinyl Chloride
ND
<.0010 mg/1

OCPSF Related Parameters
Permit No. NC 0003719
PARAMETER NAME
2006
February
May
August
November
Accnaphthene
ND
<0.010mg/1
Acenaphthylene
ND
<0.010mg/1
Acrylonitrile
ND
<0.050mg/I
Anthracene
ND
<0.010mg/l
Benzene
ND
<0.0010mg/1
Benzo(a)anthracene
ND
<0.010mg/I
3,4-Benzofluranthene
ND
<0.010mg/1
Benzo(k)fluoranthene
ND
<0.010mg/1
Benzo(a)pyrene
ND
<0.010mg/1
Bis(2-ethylhexyl) phthalate
ND
<0.010mg/1
Carbon Tetrachloride
ND
<0.0010mg/1
Chlorobenzene
ND
<0.0010mg/1
Chloroethane ,
ND
<0.0010mg/1
Chloroform
ND
<0.0050mg/l
2-Chlorophenol
ND
<0.010mg/1
Chrysene
ND
<0.010mg/1
Di-n-butyl phathalate
ND
<0.010mg/1
1,2-Dichlorobenzene
ND
<0.0100mg/1
1,3-Dichlorobenzene
ND
<0.0100mg/1
1,4-Dichlorobenzene
ND
<0.0100mg/1
1,1-Dichloroethane
ND
<0.0010mg/1
1,2-Dich]oroethane
ND
<0.0010mg/1
1,1-Dich]oroethylene
ND
<0.0010mg/I
1,2-trans-Dichloroethylene
ND
<0.0010mg/t
2,4-Dichlorophenol
ND
<0.010mg/1
1,2-Dichloropropane
ND
<0.0010mg/1
1,3-Dichloropropylene
ND
<0.00 10mg/1
Diethyl phthalate
ND
<0.010mg/1
2,4-Dimethylphenol
ND
<0.010mg/1
Dimethyl phthalate
ND
<0.010mg/l
4,6-Dinitro-o-cresol
ND
<0.050mg/1
2,4-Dinitrophenol
ND
<0.050mg/I
2,4-Dinitrotoluene
ND
<0.010mg/I
2,6-Dinitrotoluene
ND
<0.010mg/I
Ethylbenzene
ND
<0.0010mg/I
Fluoranthene
ND
<0.010mg/1
Fluorene
ND
<0.010mg/]
Hexachlorobenzene
ND
<0.010mg/1
Hexachlorobutadiene
ND
<0.010mg/I
Hexachloroethane
ND
<0.010mg/1
Methyl Chloride
ND
<0.0010mg/1
Methylene Chloride
ND
<0.0050mg/1
Naphthalene
ND
<0.0100mg/1
Nitrobenzene
ND
<0.010mg/1
2-Nitrophenol
ND
<0.010mg/1

Permit No. NC 0003719
PARAMETER NAME
2006
February
May
August
November
4-Nitrophenol
ND
<0.050mg/1
Phenanthrene
ND
<0.010mg/1
Phenol
ND
<0.010mg/1
Pyrene
ND
<0.010mg/1
Tetrachloroethylene
ND
<0.001 Omg/1
Toluene
ND
<0.0010mg/1
Total Chromium
ND
<.005 mg/1
<.005 mg/I
<.005 mg/I
<.005 mg/I
Total Copper
PRESENT
<.003 mg/1
<.003 mg/1
0.003msril
<.003 mg/I
Total Cyanide
ND
<.005 mg/1
<.005 mg/1
<.005 mg/1
<.005 mg/1
Total Lead
ND
<.003 mg/I
<.003 mg/I
<.003 mg/1
<.003 mg/1
Total Nickel
ND
<.005 mg/1
<.005 mg/1
<.005 mg/1
<.005 mg/1
Total Zinc
PRESENT
.017 mg/I
.016 m!,/1
032 mall
.0t0 mg/I
1,2,4-Trichlorobenzene
ND
<0.0010mg/1
1,1,1-Trichloroethane
ND
<0.0010mg/I
1,1,2-Trichloroethane
ND
<0.0010mg/1
Trichloroethylene
ND
<0.0010mg/1
Vinyl Chloride
ND
<0.0010mg/I

OCPSF Related Parameters
Permit No. NC 0003719
PARAMETER NAME
2007
February
May
August
November
Acenaphthene
ND
<0.01 Omg/l
Acenaphthylene
ND
<0.010mg/1
Acrylonitrile
ND
<0.050mg/1
Anthracene
ND
<0.010mg/l
Benzene
ND
<0.0010mg/I
Benzo(a)anthracene
ND
<0.010mg/I
3,4-Benzofluranthene
ND
<0.010mg/I
Benzo(k)fluoranthene
ND
<0.010mg/I
Benzo(a)pyrene
ND
<0.010mg/1
Bis(2-ethylhexyl) phthalate
ND
<0.010mg/l
Carbon Tetrachloride
ND
<0.0010mg/I
Chlorobenzene
ND
<0.0010mg/l
Chloroethane
ND
<0.0010mg/1
Chloroform
ND
<0.0050mg/I
2-Chlorophenol
ND
<0.010mg/1
Chrysene
ND
<0.010mg/1
Di-n-butyl phathalate
ND
<0.010mg/1
1,2-Dichlorobenzene
ND
<0.0100mg/I
1,3-Dichlorobenzene
, ND
<0.0100mg/I
1,4-Dichlorobenzene
ND
<0.0100mg/1
1,1-Dichloroethane
ND
<0.0010mg/1
1,2-Dichloroethane
ND
<0.0010mg/1
1,1-Dichloroethylene
ND
<0.0010mg/1
1,2-trans-Dichloroethylene
ND
<0.0010mg/1
2,4-Dichlorophenol
ND
<0.010mg/1
1,2-Dichloropropane
ND
<0.0010mg/I
1,3-Dichloropropylene
ND
<0.0010mg/1
Diethyl phthalate
ND
<0.010mg/I
2,4-Dimethylphenol
ND
<0.010mg/I
Dimethyl phthalate
ND
<0.010mg/1
4,6-Dinitro-o-cresol
ND
<0.010mg/1
2,4-Dinitrophenol
ND
<0.010mg/l
2,4-Dinitrotoluene
ND
<0.010mg/I
2,6-Dinitrotoluene
ND
<0.010mg/I
Ethylbenzene
ND
<0.0010mg/I
Fluoranthene
ND
<0.010mg/I
Fluorene
ND
<0.010mg/1
Hexachlorobenzene
ND
<0.010mg/1
Hexachlorobutadiene
ND
<0.010mg/1
Hexachloroethane
ND
<0.010mg/1
Methyl Chloride
ND
<0.0010mg/1
Methylene Chloride
ND
<0.0050mg/1
Naphthalene
ND
<0.0050mg/1
Nitrobenzene
ND
<0.010mg/1
2-Nitrophenol
ND
<0.010mg/1

Permit No. NC 0003719
PARAMETER NAME
2007
February
May
August
November
4-Nitrophenol
ND
<0.01 Omg/1
Phenanthrene
ND
<0.010mg/1
Phenol
ND
<0.010mg/1
Pyrene
ND
<0.010mg/1
Tetrachloroethylene
ND
<0.0010mg/1
Toluene
ND
<0.0050mg/1
Total Chromium
ND
<.005 mg/1
<.005 mg/I
<.010 mg/I
<.005 mg/1
Total Copper
ND
<.003 mg/1
<.003 mg/I
<.020 mg/1
<.003 mg/1
Total Cyanide
ND
<.005 mg/1
<.005 mg/I
<.005 mg/1
<.005 mg/1
Total Lead
ND
<.003 mg/1
<.003 mg/I
<.005 mg/1
<.003 mg/1
Total Nickel
ND
<.005 mg/1
<.005 mg/1
<.020 mg/1
<.005 mg/1
Total Zinc
PRESENT
0.008 mg/I
0.016 nig/1
<.030 mg/1
1,2,4-Trichlorobenzene
ND
<0.001 Omg/1
1,1,1-Trichloroethane
ND
<0.0010mg/1
1,1,2-Trichloroethane
ND
<0.0010mg/1
Trichloroethylene
ND
<0.0010mg/I
Vinyl Chloride
ND
<0.001Omg/I

OCPSF Related Parameters
Permit No. NC 0003719
PARAMETER NAME
2008
February
May
August
November
Acenaphthene
ND
<.006 mg/I
Acenaphthylene
ND
<.006 mg/1
Acrylonitrile
ND
<.2 mg/1
Anthracene
ND
<.006 mg/1
Benzene
ND
<.001 mg/1
Benzo(a)anthracene
ND
<.006 mg/1
3,4-Benzofluranthene
ND
<.006 mg/1
Benzo(k)fluoranthene
ND
<.006 mg/1
Benzo(a)pyrene
ND
<.006 mg/1
Bis(2-ethylhexyl) phthalate
ND
<.006 mg/1
Carbon Tetrachloride
ND
<.001 mg/1
Chlorobenzene
ND
<.001 mg/1
Chloroethane
ND
<.001 mg/1
Chloroform
ND
<.001 mg/1
2-Chlorophenol
ND
<.006 mg/1
Chrysene
ND
<.006 mg/I
Di-n-butyl phathalate
ND
<.006 mg/I
1,2-Dichlorobenzene
ND
<.001 mg/I
1,3-Dichlorobenzene
ND
<.001 mg/1
1,4-Dichlorobenzene
ND
<.001 mg/1
1,1-Dichloroethane
ND
<.001 mg/1
1,2-Dichloroethane
ND
<.001 mg/1
1,1-Dichloroethylene
ND
<.001 mg/1
1,2-trans-Dichloroethylene
ND
<.001 mg/1
2,4-Dichlorophenol
ND
<.006 mg/1
1,2-Dichloropropane
ND
<.001 mg/1
1,3-Dichloropropylene
ND
<.001 mg/I
Diethyl phthalate
ND
<.006 mg/1
2,4-Dimethylphenol
ND
<.006 mg/1
Dimethyl phthalate
ND
<.006 mg/1
4,6-Dinitro-o-cresol
ND
<.03 mg/I
2,4-Dinitrophenol
ND
<.03 mg/I
2,4-Dinitrotoluene
ND
<.006 mg/I
2,6-Dinitrotoluene
ND
<.006 mg/I
Ethylbenzene
ND
<.001 mg/I
Fluoranthene
ND
<.006 mg/I
Fluorene
ND
<.006 mg/I
Hexachlorobenzene
ND
<.006 mg/I
Hexachlorobutadiene
ND
<.006 mg/1
Hexachloroethane
ND
<.006 mg/1
Methyl Chloride
ND
<.001 mg/1
Methylene Chloride
ND
<.005 mg/1
Naphthalene
ND
<.006 mg/1
Nitrobenzene
ND
<.006 mg/1
2-Nitrophenol
ND
<.006 mg/1

Permit No. NC 0003719
It PARAMETER NAME
2008
February
May
August
November
4-Nitrophenol
ND
<.03 mg/1
Phenanthrene
ND
<.006 mg/1
Phenol
ND
<.006 mg/1
Pyrene
ND
<.006 mg/1
Tetrachloroethylene
ND
<.001 mg/1
Toluene
ND
<.001 mg/1
Total Chromium
ND
<.005 mg/I
<.005 mg/I
<.005 mg/1
<.005 mg/I
Total Copper
ND
<.003 mg/I
<.003 mg/I
<.003 mg/1
<.003 mg/I
Total Cyanide
ND
<.005 mg/I
<.005 mg/I
<.005 mg/1
<.005 mg/I
Total Lead
ND
<.003 mg/I
<.003 mg/I
<.003 mg/I
<.003 mg/1
Total Nickel
PRESENT
<.005 mg/1
.018 mg/I
<.005 mg/I
<.005 mg/]
Total Zinc
PRESENT
0.008 mg/1
0.032 mill
0.014 mg/1
,,;,;,,,0.056 mg/1
1,2,4-Trichlorobenzene
ND
<.006 mg/I
1,1,1-Trichloroethane
ND
<.001 mg/I
1,1,2-Trichloroethane
ND
<.001 mg/I
Trichloroethylene
ND
<.001 mg/1
Vinyl Chloride
ND
<.001 mg/l

Permit Facility Outfall Month Day Year Comment Parameter Sample UoM Value Modifier Loc
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 2 5 2002 <0.025 34626 - 2,6-dinitrotoluene Grab Ibs/day LESSTHAN Effh.
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 2 6 2002 <0.025 34626 - 2,6-dinitrotoluene Grab lbs/day LESSTHAN Effigy
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 5 2 2002 <0.023 34626 - 2,6-dinitrotoluene Grab lbs/day LESSTHAN Efflt;
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 5 27 2002 <0.023 34626 - 2,6-dinitrotoluene Grab lbs/day HOLIDAY Efflt.
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 8 7 2002 <0.033 34626 - 2,6-dinitrotoluene Grab Ibs/day LESSTHAN Efft.
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 11 14 2002 <0.043 34626 - 2,6-dinitrotoluene Grab Ibs/day LESSTHAN Effk.
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 8 6 2003 <.035 34626 - 2,6-dinitrotoluene Grab Ibs/day LESSTHAN Eff1L
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 8 10 2005 <0.022 34626 - 2,6-dinitrotoluene Grab Ibs/day LESSTHAN EfflL
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 8 9 2006 < 0.021 34626 - 2,6-dinitrotoluene Grab Ibs/day LESSTHAN Efflt.
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 8 15 2007 <.018 34626 - 2,6-dinitrotoluene Grab Ibs/day LESSTHAN Efflt.
NC0003719 DAK Americas, LLC - Cedar Creek Site 002 8 6 2008 34626 - 2,6-dinitrotoluene Grab Ibs/day 0.012 LESSTHAN Efflt;

Permit Versio Facility
NC0003719 2.00 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.00 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.00 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.00 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.00 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.00 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.10 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.10 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.10 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.10 DAK Americas, LLC - Cedar Creek Site
NC0003719 2.10 DAK Americas, LLC - Cedar Creek Site
Outfall Month Day Year Comment
002 2 5 2002 <0.032
002 2 6 2002 <0.032
002 5 1 2002 <0.021
002 5 27 2002 <0.021
002 8 6 2002 <0.030
002 11 14 2002 <0.034
002 8 6 2003 <.035
002 8 10 2005 <0.022
002 8 9 2006 < 0.021
002 8 15 2007 <.018
002 8 6 2008
Parameter
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
39700 - Hexachlorobenzene
Sample UoM
Composite ug/I
Composite ug/I
Composite ug/I
Composite ug/I
Composite ug/l
Composite ug/I
Composite ug/I
Composite ug/I
Grab lbs/day
Grab lbs/day
Composite ug/I
Value Modifier
LESSTHAN
LESSTHAN
LESSTHAN
HOLIDAY
LESSTHAN
LESSTHAN
LESSTHAN
LESSTHAN
LESSTHAN
LESSTHAN
0.012 LESSTHAN

DAK Americas
May 27, 2009
Mr. Joe R. Corporon, L.G.
NPDES Program, East
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27604
Subject: NPDES Permit Draft
Permit No. NC0003719
DAK Americas LLC - Cedar Creek Site
3468 Cedar Creek Road
Fayetteville, NC 28301
Cumberland County
Dear Mr. Corporon:
RECEIVED
MAY 2 9 2009
DENR - WATER OUALrIY
POINT SOURCE BRANCHco
DAK Americas received the draft NPDES permit for its Cedar Creek Site on Tuesday, April
28, 2009. We have concerns with the permit as drafted, particularly with regards to the Divi-
sion's decision to terminate the permit on October 31, 2011, the lower limits for BOD and
other parameters, and the omission of the recycle bottle plant in the development of the site's
permit limits.
Detailed comments and an updated Engineering Alternatives Analysis are attached.
DAK looks forward to working with the Division to renew the site's NPDES permit. If you
have questions, please call me at [phone].
Sincerely,
Eli Beth Wike
Environmental Engineer
Water Quality Management
Attachment
Cape Fear Site • 3500 Daniels Road NE • P.O. Box 2260 • Leland, NC 28451
877-432-2766 (toll -free) • 910-371-4000 (phone) • 910-371-4179 (fax)
www.dakamericas.com

DAK Americas Comments
NPDES Permit Draft
Dated April 22, 2009
Received by DAK Americas on April 28, 2009.
From the cover letter for the draft permit the Division writes:
Review of the Renewal Application and Engineering Alternatives Analysis (EAA) —
The Division has reviewed DAK's updated permit Renewal Application (received
December 11, 2008) and its associated revised Engineering Alternatvie Analysis
(EAA) received March 5, 2008. The division notes that the Permittee's lowest cost -
estimate comparison of viable discharge alternatives falls within 13% considering,
a) remaining connected to the Fayetteville PWC, or b) continuing discharge to the
Cape Fear River. Historically, the Division has considered EAA discharge -
alternative costs equally viable if within 15%. In light of water quality considera-
tion and the Division's mission to eliminate discharges, we ask that you reconsider
your choice to abandon your active city sewer connection and to continue surface -
water discharge to the Cape Fear River.
Decision Against Further Renewal — The Division understands that DAK currently
discharges approximately 0.030 MGD (about 15%) of its treated effluent via the
city sewer system to the Fayetteville PWC, and has done so since May 1, 2006 un-
der the PWC's Pretreatment Program. Considering the Division NPDES directives
to eliminate a point -source discharge when faced with a viable discharge alterna-
tive, the DWQ will not consider further application to renew this permit. It follows
then that, DAK must abandon all treated effluent discharge to the Cape Fear River,
and make all changes and upgrades necessary to convey 100% of its effluent flow
to the City of Fayetteville. The Division has therefore added a permit special con-
dition requiring this compliance on or before permit expiration on October 31,
2011. (see permit Special Condition A. (5.).
DAK's Response
Despite DENR's 15% threshold, DAK's cost to treat the wastewater and then to pay PWC to
take fully -treated wastewater is indeed significant. At any time, but especially in the current
economic recession, having to absorb an increase of nearly 15% puts an undue burden on all
of the businesses on the site. The amount of money needed to send all of the wastewater to
PWC and have this water retreated will be approximately $400,000 per year.
When DAK resubmitted the permit application to include the construction of the recently an-
nounced recycle bottle facility, DAK did not think it necessary to update the EAA because,
even though the cost numbers would be somewhat different, DAK believed the conclusion
would remain the same: It is not economically sound to pay to treat the wastewater and then
to pay PWC to take fully -treated wastewater. However, after receiving the draft permit,
DAK has decided to revise the EAA to include the additional water flows and the updated
capital and operating costs associated with the recycle bottle plant. The revised EAA is at-
tached. This analysis shows that the cost of discharging fully -treated wastewater to PWC is
24.4% higher than continuing to discharge to the Cape Fear River.

DAK does not want to abandon the active city sewer connection. DAK has requested to
maintain the ability to discharge both to the Cape Fear River and to PWC. The line to PWC
would remain in place.
Additional Comments
The Division has made a number of additional changes to the previous permit. Each change
proposed in the draft permit is listed below followed by DAK's comments.
1. Revised Flow and Wastewater Treatment Plant Downgrade — Based on DAK's revised
flow estimates (2007), the Division has lowered the permit flow limit at Outfall 002
from 0.500 to 0.300 MGD to accommodate the full range of the 2007 estimates. With
this decrease in permitted flow DWQ has downgraded this wastewater treatment plant
from Grade III to Grade II. Therefore, monitoring frequencies for many parameters
have been relaxed from 3/week to 1/week (see permit, Part A.1).
DAK's Comments
DAK requests that the wastewater treatment plant remain a Grade III facility with a
permitted flow of 0.500 MGD. Table 1 shows the effluent flow by month for the period
from 2004 to 2008. Table 2 shows the average annual effluent flow for the same pe-
riod. Five of the months during this period would have been over the proposed 0.300
MGD. Using the flows from a single year to determine the permitted flow may not
work in all cases because a single year may not represent the full range of plant opera-
tions. It should also be noted that 2007 was a drought year and flows were reduced by
the drought conditions.
In addition, DAK has requested that the NDPES permit be modified to include waste-
water from the recycle bottle plant. That flow, as shown in the application, is an in-
crease of 0.111 MGD. Therefore total effluent flow will be 0.228 MGD plus 0.111
MGD which equals 0.339 MGD. A permitted maximum flow of 0.300 MGD is below
what the flow will be once the recycle bottle plant is operational; but a permitted flow
of 0.500 would allow for the expansion.
2. Effluent Limits and Monitoring Conditions — The Division recalculated limits for pa-
rameters of concern required under federal categorical regulations for Organic Chemi-
cals, Plastics and Synthetic Fibers (OCPSF) in compliance with §40 CFR 414.40, Sub-
part D, 414.41 Best Available Technology (BAT) for Thermoplastic Resins, and §414.91
9b), Subpart I for Direct Discharge Point Sources That Use End -of -Pipe Biological
Treatment. The Division applied these calculation using a long-term average flow as
recommended by EPA) of 0.200 MGD based on data submitted by the Permittee (Janu-
ary 2005 through December 2008).
DAK's comments
The permit makes changes to the permit limits for BOD5 and other parameters It is un-
clear how the BOD5 limits in the draft permit were calculated. The Division used the
flow of 0.200 MGD to develop the permit limits.
As DAK understands the calculation, the BOD5 limit should be based the effluent

guidelines (§40 CFR 414.40, Subpart D, 414.41 Best Available Technology (BAT) for
Thermoplastic Resins) of 64 mg/L for the Daily Maximum and 24 mg/L for the
Monthly Average. Using an effluent flow of 0.200 MGD, the calculation for BOD5
would be:
BOD5 Daily Maximum = 0.200 MGD x 64 mg I L x 8.341b / gal =106.8 lb / day
BOD5 Monthly Average = 0.200 MGD x 24 mg / L x 8.34 lb / gal = 40.0 lb / day
The draft permit shows the monthly average BOD5 limit of 16 lbs/day for April 1 —
October 31 and 32 lbs/day for November 1— March 31. It also shows the Daily Maxi-
mum to be 21 lbs/day for April 1— October 31 and 42 lbs/day for November 1— March
31.
The DAK Resins and the DuPont Resins operations are both OCPSF regulated indus-
tries; however, the recycle bottle plant will operate under a SIC code of 5162 as shown
on EPA Form 1 in the application. SIC code 5162 is not an OCPSF-regulated industry
nor does it have an associated effluent guideline.
DAK requests that the permit limits be calculated from the effluent guidelines using the
total long-term average flow from the DAK and DuPont operations of 0.228 MGD as
shown in Table 3 for the period of 2005-2008 plus the flow from the recycle bottle fa-
cility of 0.111 MGD.
As stated above, there are no effluent guidelines associated with the new recycle facil-
ity's SIC code. Since the recycle facility will work with polyester materials as does
both the DAK resins and the DTF facility, DAK is proposing to use the same effluent
guidelines for the recycle facility as for the resins operations in DAK and DTF.
Based on this, DAK proposes the discharge limits as shown in Table 4.
3. Total Residual Chlorine (TRC) DAK has no comments with regard to the addition of
a TRC limit in the draft permit.
4. Stormwater Outfalls — DAK is requesting that the NPDES permit be renewed to allow
continued discharge of treated effluent to the Cape Fear River. DAK had hoped to
consolidate the stormwater permit and the NPDES permit into a single permit to ease
the administrative burden of managing two permits.
5. Proposed Plastic Bottle Recycling Facility — DAK has asked the Division to permit a
proposed new onsite plastic bottle recycling facility. The Division understands that
OCPSF-regulated process -contact wastes will be generated from two existing ware-
houses (located near DAK's eastern property perimeter); wastes to be routed to the ex-
isting onsite WWTP. We further understand that DAK intends to provide an open, un-
covered area north of these warehouses for product bulk storage. The recycle facility is
hereby permitted;, however its effluent flow, waste concentrations, and stormwater
needs remain uncharacterized.

Therefore, after receiving an Authorization to Construct (ATC) permit from the Divi-
sion's Construction Grants and Loans, please provide information concerning flow,
waste character, and stormwater needs, prior to start-up, so that the Division may
modify permit, if needed.
DAK's Comments
The flow for the recycled bottle facility of 0.111 MGD was included in the revised ap-
plication dated December 8, 2008. In order to design the appropriate upgrade to the
WWTP, DAK needs to know what the permit limits will be for the site once the recycle
bottle plant is completed. Moreover, it is DAK's understanding that the Construction
Grants and Loans group will not accept an ATC application without knowing what
permit limits apply to the reconfigured facility.
The existing DAK and the DuPont operations are both OCPSF regulated industries;
however, the recycle bottle plant will operate under a SIC code of 5162 as shown on
EPA Form 1 in the application. SIC code 5162 is not an OCPSF-regulated industry nor
does it have an associated effluent guideline.
The Division did not consider any effluent guidelines for the recycle bottle plant in de-
veloping the permit limits shown in the draft permit. DAK is proposing that the effluent
guidelines for the recycle bottle plant be the same as for the DAK resin and DTF plants.
This is because all three facilities work mainly with polyester materials. The limits
shown in Table 4 were developed assuming these effluent guidelines.
We believe it is very important that the permitting of the recycled bottle facility be ade-
quately addressed in this permit so that construction of this facility can proceed without
delay. This economic development project is important, not only to the company, but to
the community because of the creation of jobs, increased tax base, and other economic
benefits to the community.
Summary
DAK requests that the Division renew the Cedar Creek NDPES permit, remove the special
condition that would prohibit renewal of the permit, increase the permitted flow from 0.300
MGD to 0.500 MGD, revise the limits for BOD, TSS, NH3-N, and other parameters based on
the effluent guidelines, and include the recycle bottle facility in the development of the site's
limits.
If you have any questions, please call Elizabeth Wike at [phone].

Table 1- Effluent Flows by Month
Effluent Flow Effluent Flow
Cape Cape
Fear Monthly Fear Monthly
Month River PWC Average Month River PWC Average
MGD MGD MGD MGD MGD MGD
Jan-04 0.264 0.264 Jan-07 0.212 0.030 0.242
Feb-04 0.138 0.138 Feb-07 0.243 0.030 0.273
Mar-04 0.248 0.248 Mar-07 0.172 0.028 0.200
Apr-04 0.239 0.239 Apr-07 0.176 0.032 0.208
May-04 0.194 0.194 May-07 0.131 0.030 0.161
Jun-04 0.301 0.301 Jun-07 0.173 0.031 0.203
JuI-04 0.304 0.304 JuI-07 0.145 0.031 0.176
Aug-04 0.333 0.333 Aug-07 0.180 0.031 0.211
Sep-04 0.357 0.357 Sep-07 0.218 0.030 0.248
Oct-04 0.201 0.201 Oct-07 0.133 0.030 0.163
Nov-04 0.190 0.190 Nov-07 0.106 0.030 0.136
Dec-04 0.180 0.180 Dec-07 0.181 0.031 0.212
Jan-05 0.193 0.193 Jan-08 0.205 0.030 0.235
Feb-05 0.183 0.183 Feb-08 0.181 0.030 0.211
Mar-05 0.181 0.181 Mar-08 0.191 0.031 0.221
Apr-05 0.173 0.173 Apr-08 0.207 0.029 0.236
May-05 0.105 0.105 May-08 0.160 0.031 0.191
Jun-05 0.208 0.208 Jun-08 0.152 0.030 0.182
Jul-05 0.300 0.300 JuI-08 0.197 0.031 0.228
Aug-05 0.258 0.258 Aug-08 0.264 0.031 0.295
Sep-05 0.190 0.190 Sep-08 0.279 0.031 0.310
Oct-05 0.225 0.225 Oct-08 0.128 0.030 0.158
Nov-05 0.238 0.238 Nov-08 0.194 0.031 0.225
Dec-05 0.264 0.264 Dec-08 0.198 0.032 0.230
Jan-06 0.217 0.217
Feb-06 0.219 0.219
Mar-06 0.172 0.172
Apr-06 0.161 0.161
May-06 0.157 0.003 0.160
Jun-06 0.260 0.260
JuI-06 0.234 0.234
Aug-06 0.242 0.022 0.264
Sep-06 0.252 - 0.252
Oct-06 0.187 - 0.187
Nov-06 0.291 - 0.291
Dec-06 0.226 0.030 0.256

Table 2 - 2004-2008 Annual Average Effluent Flows
Effluent Flow Annual Average
Cape
Max
Fear
Annual
Monthly
River
PWC
Average
Average
Year
MGD
MGD
MGD
MGD
2004
0.246
-
0.246
0.357
2005
0.210
-
0.210
0.300
2006
0.213
0.003
0.215
0.291
2007
0.172
0.030
0.203
0.273
2008
0.196
0.030
0.227
0.310
Table 3 - Long-term Average Effluent Flows
Long term
average
Cape
Fear
River
PWC
Annual
Average
Max
Monthly
Average
MGD
MGD
MGD
MGD
2004-2008
2005-2008
0.207
0.198
0.030
0.030
0.237
0.228
0.357
0.310
Table 4 - Calculated Permit Limits for BOD and TSS
Flow
BOD
TSS
Daily Max
Monthly Av-
erage
Daily Max
Monthly Av-
erage
DAK and DuPont
Recycle Bottle Facility
Total
0.228 MGD
0.111 MGD
64 mg/L
64 mg/L
24 mg/L
24 mg/L
130 mg/L
130 mg/L
40 mg/L
40 mg/L
0.339 MGD
Calculated
Permit Limits
180.8 lbs/day
67.8 lbs/day
367.3 lbs/day
113.01bs/day

Engineering Alternatives Analysis
Permit No. NC0003719
DAK Americas LLC - Cedar Creek Site
3468 Cedar Creek Road
Fayetteville, NC 28301
Cumberland County
Pim111 STEARNS & WHELER A
CLILW IS PLOPLL PCNI ONtAAkCC
May 27, 2009
DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Table of Contents
Section 1 Introduction 1-1
1.1 Purpose 1-1
1.2 Report Outline 1-1
Section 2 General Information 2-1
2.1 Plant Description 2-1
2.2 Current Wastewater Flows and Loading 2-4
Section 3 Wastewater Disposal Alternatives Analysis 3-1
3.1 Alternative No. 1— No Capital Improvements to WWTP and Maintain NPDES
Permit 3-1
3.2 Alternative No. 2 — Upgrade WWTP and Maintain NPDES Permit 3-2
3.3 Alternative No. 3 — Discharge Untreated Wastewater to PWC 3-4
3.4 Alternative No. 4 — Upgrade WWTP and Discharge to PWC 3-5
3.5 Alternative No. 5 — No Upgrades to the WWTP and Discharge Treated Effluent
to PWC 3-6
3.6 Alternative No. 6 — Land -based Disposal Systems 3-7
3.7 Alternative No. 7 — Wastewater Reuse 3-9
Section 4 Summary of Costs 4-1
4.1 Capital Costs 4-1
4.2 Operations and Maintenance Costs 4-1
4.3 Net Present Value Analysis 4-3
Section 5 Recommendation 5-1
-^ STEARNS & WHELER
CLILNTS'PLOPLL PERI OHMANCL
DAK Americas
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
2-4 Wastewater Characteristics
4-1 Probable Capital Costs
4-2 Probable O&M Costs
4-3 Net Present Value of Alternatives
List of Figures
Figure
1 Wastewater Treatment Facility Aerial Photo
2 Wastewater Treatment Plant Process Flow Diagram
Appendix
Appendices
A Fayetteville PWC — Industrial User Wastewater Survey and Permit Application
STEARNS & WHELER
CLILN I Si:PLOPLL PHI ORtlANCL
DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Section 1 Introduction
1.1 Purpose
DAK Americas prepared an Engineering Alternatives Analysis (EAA) in 2004 in support of
its acquisition of Monsanto Agricultural Company's wastewater treatment facility
located on Cedar Creek Road in Fayetteville, North Carolina. At the request of the
Division of Water Quality (DWQ), DAK updated the EAA in 2008 to reflect more current
operational costs. The analysis contained herein further updates the EAA to capture the
costs of operating a recycled bottle processing operation, due to go online in the fourth
quarter of 2009. The objective of this EAA 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;
• Industrial Pretreatment permit requirements issued by the Fayetteville Public Works
Commission (PWC);
• Evaluation of disposal alternatives, as outlined in the EAA guidance document;
• Net Present Value analysis of potential disposal alternatives;
• Recommendations for wastewater disposal.
11111111114 STEARNS & WFiELER
CLICNI S PLOPLL PLHF OHMANGL
1-1
DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Section 2 General Information
2.1 Plant Description
The former Monsanto Wastewater Treatment Facility, presently owned and operated by
DAK Americas, is located on Highway 53 (Cedar Creek Road), south of Fayetteville in
Cumberland County. The Cedar Creek WWTP treats wastewater from the DAK Americas
and the DuPont Teijin Films facilities. Treated wastewater is discharged into the Cape
Fear River, which is a 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 Americas, 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 components listed in Table 2-2.
STEARNS & WHELER
7 CLILN LS PL°PLL PLRI" °RMAN.C..L
2-1
DAK Americas
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 Tined 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 140,000 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. 1
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 150 (Hp) aerators.
Extended Aeration
Activated Sludge Process
Aeration Basin No. 2
Aeration basin No.2 is a 1.2 MG concrete basin with a
6.5-foot side water depth and equipped with seven
aerators and two 75 hp mixers. Five aerators are
fixed (two 40 hp, two 50 hp, and one 75 hp) and two
floating aerators, each 40 hp.
Chemical Lift Station
Two pumps; one duty pump with a capacity of 160
gpm and a second stand-by unit with a capacity of
300 gpm.
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 with a capacity of
900 gpm. Common discharge manifold.
Parshall Flume
One Parshall flume is used for measuring flow
discharged from the facility.
Aerobic Digester
One in -ground concrete basin equipped with surface
aerators. Digester has a capacity of 0.550 MG and is
equipped with two 25 horsepower aerators.
Sludge Storage Basin
One 1.0 MG in -ground concrete basin with two 25
horsepower mixers.
Sludge Drying Beds
Three sludge drying beds, each 240 feet by 30 feet.
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CLILN.rSPLOPLL PERI OHMANCL `J
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

A process flow diagram of the existing treatment facility is provided in Figure 2. A brief
description of the process flow follows.
Wastewater generated from resin manufacturing at the DAK facility and the DuPont
Teijin Films facility is 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. Steam, formerly used to increase wastewater temperature during
winter months has been discontinued.
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 is
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 are wasted to the aerobic
digester.
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

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. Dewatered solids are disposed of at Sampson County landfill. Decant from
the 1.0 MG sludge settling basin is returned to the aeration basin.
Table 2-3 summarizes the average operational parameters for the activated sludge
process.
TABLE 2-3
AVERAGE OPERATIONAL PARAMETERS (2008)
Parameter
Value
Mixed Liquor Suspended Solids (MLSS)
3,699 mg/L
Mixed Liquor Volatile Suspended Solids (MLVSS)
3,364 mg/L
MLVSS/MLSS Ratio
0.91
Food to Microorganism ratio (F/M)
0.09
Solids Retention Time (SRT)
69 days
Secondary Clarifier Underflow Concentration
4.411 mg/L
PH
7.3
2.2 Current Wastewater Flows and Loading
The flows and wastewater constituents are representative of the blended wastewater
from the DAK Americas 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
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

facilities already implement reuse of plant process water and employ low -flow devices
where applicable to reduce wastewater generation.
Table 2-4 summarizes the 2008 minimum, average, and maximum flows and influent
loadings to the treatment facility.
TABLE 2-4
2008 WASTEWATER CHARACTERISTICS
Parameter
Minimum
Average
Maximum
Effluent Flow (god)
35,000
227,000
600,000
Chemical Oxygen Demand, COD (mg/L)
536
2,289
17,265
Chemical Oxygen Demand, COD (Ib/day)
758
3,041
11,375
Total Suspended Solids, TSS (mg/L)
5
183
1,170
pH
3.53
4.33
7.05
Temperature (°C)
16.6
30.7
47.1
STEARNS & WHELER T
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7-5
DAK Americas
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. For the purposes of calculating
costs, actual flows were used. The long-term average OCPSF flow was determined to be
approximately 0.228 mgd (this includes 0.2 currently discharged via NPDES permit and
0.028 currently discharged to PWC). In addition, the new recycled bottle operation will
contribute approximately 0.111 mgd to the Cedar Creek WWTP. As such, the flow used
for developing alternative costs is 0.339 mgd.
Each alternative below includes the capital cost of $1.46 million and $150,000 Operating
and Maintenance costs to upgrade the wastewater treatment plant to support the new
recycled bottle facility
3.1 Alternative No. 1— No Capital Improvements to
WWTP and Maintain NPDES Permit
Alternative No. 1 involves operating the existing wastewater treatment plant without
any modifications other than those required to support the recycled bottle facility
because it currently provides secondary treatment within the NPDES permit limits
established when Monsanto Agriculture Company owned the facility. This alternative
does not, however, account for improvements that would allow the existing WWTP to
operate more cost effectively.
STEARNS & WHELER
.._ .-
INA
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3-1
DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

The advantages of this alternative include:
1. No capital investment at this time to meet the current NPDES requirements
except for those required to support the recycled bottle facility.
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.
3.2 Alternative No. 2 — Upgrade 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. It also includes the capital and O&M costs necessary to
support the recycle bottle facility. The proposed improvements in addition to those
required for the recycled bottle plant 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,
PMIINI STEARNS & WHELER
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

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. 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.
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.
Regardless, both alternatives appear similar in cost and neither are necessary for the
facility to continue to comply with its NPDES and PWC discharge permits.
Some advantages of an upgraded WWTP are:
1. Significantly reduces power consumption.
2. Reduces chemical feed requirements.
3. Reduces sludge production.
4. Site is attractive for recruiting other industries.
Some disadvantages are:
1. Significant capital investment for unquantifiable O&M savings.
STEARNS & WHELER
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

2. Construction sequencing would be critical to maintain production and ensure
compliance with the NPDES permit.
3. Continued solids disposal.
3.3 Alternative No. 3 — Discharge Untreated
Wastewater to PWC
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 to abandon its wastewater treatment facility eliminating
the need for further capital investment and eliminating significant power consumption
costs, it would result in DAK being subject to discharge user fees for flow and surcharges
for high organic loadings. Current PWC sewer charges are $3.34 per 1,000 gallons. Based
on 0.339 mgd the cost would be over $400,000 excluding surcharges. The surcharges
would be prohibitive given the high COD of the untreated wastewater, which in 2008
averaged 2,289 mg/L with a maximum of 17,265 mg/L. Therefore, the cost savings
associated with abandoning the Cedar Creek WWTP must be compared to the costs of
increased wastewater fees from Fayetteville PWC.
PWC issued a revised pretreatment permit to DAK on January 1, 2009. There are no
categorical pretreatment standards in 40 CFR 414, discharge regulations for Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF). Facilities must thus comply with 40
CFR 403 and all limits developed and implemented by the permit issuing authority, PWC
in this case. The permit limits flow to 0.075 mgd and CBOD and TSS to 25.0 mg/L. A
copy of the industrial wastewater permit issued by PWC is provided in Appendix A.
STEARNS & WHELER
CLLNI SiPLOPLL PLRI ORMANCL
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

While it may be possible for PWC to increase the CBOD limit, it is unlikely it could
increase it sufficiently so that DAK could shutdown its wastewater treatment plant.
From the standpoint of plant operations, the permit limits for CBOD and TSS contained
in the pretreatment permit are essentially as restrictive as those contained in the NPDES
permit.
This alternative is not considered feasible because of the requirement to pretreat the
wastewater prior to discharge to PWC's system, and the high level of treatment
currently necessary to meet the pretreatment permit limitations established by PWC.
3.4 Alternative No. 4 — Upgrade WWTP and
Discharge to PWC
In addition to the capital and O&M costs necessary to support the recycle bottle 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. While it may be possible for PWC to
increase the CBOD limit and other permit parameters somewhat, upgrading the WWTP
only slightly reduces DAK's operating and maintenance costs. As with Alternative No. 3,
a modified biological 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 to discontinue its NPDES permit.
2. Significantly reduces power consumption.
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CLILNI SIPLOPLL PLR[ OHMANCL / L\
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

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 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 WWTP
and Discharge Treated Effluent to PWC
Under this alternative, effluent from the Cedar Creek WWTP would be conveyed by
pump station and force main to a nearby lift station operated by the City of Fayetteville.
In addition the WWTP would be upgraded to support the recycle bottle facility.
Advantages include:
1. No capital improvements would be required for the wastewater treatment
facility.
2. Allows DAK to discontinue its NPDES permit.
Disadvantages include:
1. DAK would be subject to surcharge fees, when effluent quality exceeds the
industrial pretreatment requirements.
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

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 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.
DAK 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.
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. 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.
STEARNS & WHELER
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

According to the County's soil survey map, the soil at the DAK 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 1.0allon 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.
The existing site conditions, wastewater composition, and storage requirements
required for a land disposal system makes implementation of such an alternative
challenging at best. Additional land for a land -based disposal alternative is not
immediately adjacent to the wastewater treatment facility and would need to be
acquired. Land acquisition costs, in consort with additional costs associated with
STEARNS & WHELER
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Engineering Alternatives Analysis

pumping and distribution of wastewater to the property make this alternative cost -
prohibitive and impractical. As such, 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 current permitted capacity of 500,000 gpd.
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 and reverse osmosis technologies to remove minerals
harmful to the manufacturing process. Based on the current costs (capital and
operations and maintenance) of such systems, this alternative is currently considered
cost prohibitive and has not been evaluated further.
POINN STEARNS & WHELER
CLILNIS PLOPLL PLR! ORMANCL
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DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Section 4 Summary of Costs
4.1 Capital Costs
An opinion of probable capital cost for the most viable alternatives is summarized
below. The capital improvements identified for Alternatives 2 and 4 to reduce O&M
costs are estimated at $960,000. Alternatives 1, 2, 4, and 5 all include a capital
expenditure of $1,460,000 to accommodate flows from the recycled bottle operation.
TABLE 4-1
PROBABLE CAPITAL COSTS
Alternative
Opinion of Probable
Capital Costs
No.
Description
1
No Upgrades to Cedar Creek WWTP and
Maintain NPDES Permit
$1,460,000
2
Upgrade Cedar Creek WWTP and Maintain
NPDES Permit
$2,420,000
4
Upgrade Cedar Creek WWTP and Discharge
to Fayetteville PWC
$2,420,000
5
Discharge Treated Wastewater To
Fayetteville PWC
$1,460,000
4.2 Operations and Maintenance Costs
Probable operations and maintenance costs for Alternatives 1, 2, 4, and 5 are
summarized below. The current sewer charge from PWC is $3.34 per 1000 gallons per
day. Recurring costs for Alternatives 2, 4, and 5 are generally lower than those for
Alternative 1. For the purposes of this analysis, it was assumed that DAK will realize
O&M cost savings due to the facility upgrades for alternatives 2 and 4. In addition, O&M
costs were reduced for alternatives 4 and 5 to reflect potential savings associated with
, STEARNS & WHELER DAK Americas
CLICN IS',PCOPLL PLR( OHMANCL 4-1
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

meeting slightly different effluent limitations when discharging to PWC. These
reductions are based on an assumption that higher limits could be obtained from PWC.
In addition, it is not certain that the lower O&M costs could be obtained. That said,
there is currently no practical difference between the NPDES limits and PWC limits, and
therefore little to no difference in the true cost of WWTP operation between the two
alternatives.
TABLE 4-2
PROBABLE O&M COSTS
Alternative 1 2 4 5
Description
Maintain
NPDES with
Existing
WWTP
Uprade
Cedag Creek
WWTP and
Maintain
NPDES
Cedar rCrdeek e
WWTP and
Discharge to
PWC
Discharge to
PWC with
existing
WWTP
POTW Charge for
Flow
0
0
413,275
413,275
Electricity
63,895
60,000
45,000
47,921
Maintenance
100,000
50,000
37,500
75,000
Lab Expense
51,445
51,445
51,445
51,445
Administrative
120,000
120,000
120,000
120,000
Nutrients and Misc.
Chemicals
35,000
35,000
26,250
26,250
Polymers
146,000
146,000
109,500
109,500
Sludge Disposal
128,000
128,000
96,000
96,000
Additional O&M due
to recycled bottle
operation
150,000
150,000
150,000
150,000
Totals
794,340
740,445
1,048,970
1,089,391
STEARNS & WHELER
CLILWI S'; PCOPLL PCRI OHMA4CC LOLN,
4-2
DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

4.3 Net Present Value Analysis
The Net Present Value (NPV) for each alternative is presented in Table 4-3. The net
present values are based upon a discount rate if 4.875 percent, which is the current
guidance from Construction Grants and Loans, and a term of 20 years. The P/A factor
using these criteria is 12.595.
Table 4-3
Net Present Value of Alternatives
Alternative
1
2
4
5
Capital Cost
$1,460,000
$2,420,000
$2,420,000
$1,460,000
Recurring Cost
$794,340
$740,445
$1,048,970
$1,089,391
Net Present Value
$11,464,700
$11,745,900
$15,631,800
$15,180,900
STEARNS & WHELER
GLILNISH:OPLL PLHFOHMANC.0
4-3
DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Section 5 Recommendation
Based on the alternatives evaluation, Alternative No. 1, which includes modifications to
the existing DAK wastewater treatment plant to accommodate the recycled bottle
operation and continued surface water discharge to the Cape Fear River is
recommended. The NPV for Alternative 1 is approximately 24.4% Tess than the least
expensive option for discharge to PWC.
STEARNS & WHELER_
CLILNTSIPEOPLE PLHPOHMANCE
5-1
DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Figure 2
Wastewater Treatment Plant Process Flow Diagram
ping STEARNS & WHELER
CLIENTSjPEOPLE PERE ORMANCL
DAK Americas
Cedar Creek Plant, North Carolina
Engineering Alternatives Analysis

Figure 1. DAK Americas Cedar Creek Site Wastewater Treatment System
Recycle Bottle Plant
Influent from process
Screening
DAK Resins
Influent from process
Equalization
Dupont Teijin Film
Neutralization
Screening
DAK Resins, LLC
3216 Cedar Creek Road
Fayetteville, NC
Cumberland County
NPDES Permit No. NC0003719
DAF
Equalization Tanks
A
Non -contact cooling water
Non -contact
cooling water
to stormwater
Outfall 001
Stormwater
Outfall 001
To Cape Fear River
♦
Spill Basin
Outfall 002
AB1
I
pH pit
Sanitary
Sewer
Effluent from wastewater
treatment plant
Clarifier
AB2
Digesters
To sludge storage
12/09/2008

•
r-
t

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 Americas, LLC
is hereby authorized to discharge wastewater from a facilitylocated at
3216 Cedar Creek Road
Fayetteville, North Carolina
Cumberland County
into the City of Fayetteville's municipal sanitary sewer system and municipal wastewater treatment facility
located at:
Rockfish Water Reclamation Facility
NPDES No. NC0050105
2536 Tracy Hall Rd
Cumberland County
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in parts
I, II, and III hereof.
This permit shall become effective on January 1, 2009.
This permit and the authorization to discharge shall expire at midnight on December 31, 2013.
• Signed this day of , 2008.
Steven K. Blanchard, General Manager
Public Works Commission
City of Fayetteville
North Carolina
Permit Number 2116RF
40 CFR Category 414

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

11,4
DAK Americas LLC
Permit Outline
PART I. Effluent Limitations and Monitoring Requirements
A. 1. Description of Discharge
2. Location of Monitoring Point
3. Permit Modification History
B. Effluent Limits and Monitoring Requirements
C. Monitoring and Reporting
PART II. General Permit Conditions
PART III. Special Permit Conditions
IU Name: DAK Americas. LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
3

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

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

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. B.1.EFFLUENT LIMITS AND MONITORING REQUIREMENTS
1. Receiving POTW Name: Rockfish Creek Water Reclamation Facility
Receiving POTW NPDES#: NC0050105
Effective Date for These Limits: Effective Date of this Permit
Expiration Date for These Limits: Expiration date of this Permit
Pipe #: 002 - Regulated (OCPSF) under 40 CFR 414.
This discharge shall be limited and monitored as specified below. Pollutants and
prohibitions not regulated or enumerated below shall be discharged in accordance with the
City of Fayetteville's Sewer Use Ordinance. Data collected for NPDES DMR compliance
may also be submitted to PWC and will be accepted for compliance judgment in lieu of
separate sample collection for pretreatment permit requirements.
Limited Parameter
Effluent Cmitation
in ug/I
Sample
Type
Composite
or Grab
Monitoring
Frequency(*4)
by
Permittee
By
PWC
Daily
Maximum
Monthly
Average
acenaphthene
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
Anthracene
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
Benzene
110.4
46.9
Grab
1/6 Months
1/ Calendar Year
Bis phthalate
212.59
78.3
Grab
1/6 Months
1/ Calendar Year
Carbon tetrachloride
312.12
117
Grab
1/6 Months
1/ Calendar Year
Chlorobenzene
313.1
117.0
Grab
1/6 Months
1/ Calendar Year
Chloroethane
243.1
90.6
Grab
1/6 Months
1/ Calendar Year
Chloroform
267.8
91.5
Grab
1/6 Months
1/ Calendar Year
Di-n-butyl phthalate
35.4
16.5
Grab
1/6 Months
1/ Calendar Year
1,2 dichlorobenzene
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
1,3-dichlorobenzene
313.1
117.0
Grab
1/6 Months
1/ Calendar Year
1,4-dichorobenzene
313.1
117.0
Grab
1/6 Months
1/ Calendar Year
1,1 DCA
48.6
18.1
Grab
1/6 Months
1/ Calendar Year
1,2 DCA
473.0
148.3
Grab
1/6 Months
1/ Calendar Year
1,1 DCE
49.4
18.1
Grab
1/6 Months
1/ Calendar Year
1,2 trans DCE
54.4
20.6
Grab
1/6 Months
1/ Calendar Year
1,2 Dichloropropane
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
1,3 Dichloropropylene
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
Diethyl phthalate
93.1
37.9
Grab
1/6 Months
1/ Calendar Year
Dimethly phthalate
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
4,6 Dinitro-o cresol
228.2
64.3
Grab
1/6 Months
1/ Calendar Year
Ethylbenzene
313.1
117.0
Grab
1/6 Months
1/ Calendar Year
Fluoranthene
44.5
18.1
Grab
1/6 Months
1/ Calendar Year
Fluorene
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
Hexachlorobenzene
89.1
89.1
Grab
1/6 Months
1/ Calendar Year
Hexachlorobutadiene
313.1
117.0
Grab
1/6 Months
1/ Calendar Year
hexachloroethane
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
6

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
IU Name: DAK Americas, LLC
Pennit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. B.1.EFFLUENT LIMITS AND MONITORING REQUIREMENTS
• 002 - Regulated (OCPSF) under 40 CFR 414 (continued).
Limited Parameter
Effluent Limitation
in ug/l
Sample
Type
Composite
or Grab
Monitoring
Frequency(X4)
Daily
Maximum
Monthly
Average
by
Permittee
by
PWC
Methyl chloride
243.1
90.6
Grab
1/6 Months
1/ Calendar Year
Methylene chloride
140.1
29.7
Grab
1/6 Months
1/ Calendar Year
Naphthalene
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
Nitrobenzene
5275.2
1843.3
Grab
1/6 Months
1/ Calendar Year
2-Nitrophenol
190.3
53.6
Grab
1/6 Months
1/ Calendar Year
4-Nitrophenol
474.6
133.5
Grab
1/6 Months
1/ Calendar Year
Phenanthrene
38.7
15.7
Grab
1/6 Months
1/ Calendar Year
Pyrene
39.6
16.5
Grab
1/6 Months
1/ Calendar Year
Tetrachloroethylene
135.1
42.8
Grab
1/6 Months
1/ Calendar Year
Toluene
61.0
23.1
Grab
1/6 Months
1/ Calendar Year
Total Cyanide
988.8
346.1
Grab
1/6 Months
1/ Calendar Year
Total Lead
568.6
263.7
Grab
1/6 Months
1/ Calendar Year
Total Zinc
2150.6
865.2
Grab
1/6 Months
1/ Calendar Year
1,2,4 Trichlorobenzene
654.3
161.5
Grab
1/6 Months
1/ Calendar Year
1,1,1 TCA
48.6
18.1
Grab
1/6 Months
1/ Calendar Year
1,1,2 TCA
104.6
26.4
Grab
1/6 Months
1/ Calendar Year
TCE
56.9
21.4
Grab
1/6 Months
1/ Calendar Year
Vinyl chloride
141.7
79.9
Grab
1/6 Months
1/ Calendar Year
7

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
C. Monitoring and Reporting
1. Representative Sampling
IU Name: DAK Americas, 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 on or before the tenth of the month following sample
collection. The PWC may require more frequent monitoring, or the monitoring of
additional pollutants not required in this permit, by written notification.
If the sampling performed by the permittee indicates a violation, the permittee shall
notify the PWC within 24 hours of becoming aware of the violation. The permittee
shall also repeat the sampling and analysis and submit the results of the repeat
analysis to the PWC within 30 days after becoming aware of the violation.
3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with
the techniques prescribed in 40 CFR Part 136 (U.S. Environmental Protection
Agency), and amendments thereto unless specified otherwise in the monitoring
conditions of this permit.
4. Certified Laboratory Analysis
Pollutant analysis shall be performed by a North Carolina Department of
Environmental and Natural Resources Certified Laboratory that is certified in the
analysis of the particular pollutant in wastewater.
10

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
N Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
PART I. B.2.EFFLUENT LIMITS AND MONITORING REQUIREMENTS
2. Receiving POTW Name: Rockfish Creek Water Reclamation Facility
Receiving POTW NPDES#: NC0050105
Effective Date for These Limits: Effective Date of this Permit
Expiration Date for These Limits: Expiration Date of this Permit
Pipe #: 002 - Regulated (OCPSF) under 40 CFR 414
This discharge shall be limited and monitored as specified below. Pollutants and
prohibitions not regulated or enumerated below shall be discharged in accordance with the
City of Fayetteville's Sewer Use Ordinance. Data collected for NPDES DMR compliance
may also be submitted to PWC and will be accepted for compliance judgment in lieu of
separate sample collection for pretreatment permit requirements.
Limited
Parameter
Effluent Limitation
in mg/L
Sample
Type
Composite
or Grab
Limited
Detection
Level in mg/L
(*5)
Monitoring
Frequency(7'4)
by
Permittee
(""4)
by
PWC
Daily
Maximum
Monthly.
Average
Flow .
.075 MGD
Metered (*2)
daily
CBOD
25 mg/1
Composite
2
1/month
1/6 months
TSS
25 mg/1
Composite
2
1/ month
1/6 months
Ammonia
"3
Composite
0.1
1/ month
I/6 months
Oil & Grease
250
Grab
1/ 3 months
1/6 months
Total Phos.
*3
Composite
1/3 month
1/6 months
Arsenic
*3
Composite
0.01
1/3 month
1/6 months
Cadmium
*3
Composite
0.001
1/3 month
1/6 months
Chromium
*3
Composite
0.005
1/3 month
1/6 months
Copper
*3
Composite
0.002
1/3 month
1/6 months
Cyanide
.3
Grab
0.005
1/3 month
1/6 months
Lead
*3
Composite
0.002
1/3 month
1/6 months
Mercury
"3
Composite
0.0002
1/3 month
1/6 months
Molybdenum
*3
Composite
0.1
1/3 month
1/6 months
Nickel
*3
Composite
0.01
1/3 month
1/6 months
Selenium
*3
Composite
0.01
1/3 month
1/6 months
Silver
*3
Composite
0.005
1/3 month
1/6 months
Zinc
*3
Composite
0.01
1/3 month
1/6 months
Phenol
3
Grab
1/3 month
1/6 months
Bromoform
*3
Composite
1/3 week
1/6 months
Xylene
*3
Composite
1/3 month
1/6 months
Antimony
*3
Composite
1/3 month
1/6 months
pH
*1
Grab
1/ month
1/6 months
See Page 9 for Limit Page Notes and Page 11 for Definitions.
8

f4
PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
Limits Page Notes:
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
*1 The pH shall not be less than 6.0 or greater than 11.5 standard units. pH will be
determined by field analysis on a grab sample of final effluent.
*2 Flow measurement: See Part III. Special Condition D. for additional requirements.
*3 Monitoring requirement only. If monitoring results indicate the presence of pollutants
in amounts that could cause endangerment, upset, pass -through, or hinder the
operation of the collection system or the treatment facility in any way, pollutant
specific limits may be applied.
*4 Self -monitoring requirements shall become effective the effective date of this permit.
Daily means once a day, 1/week means once a week, 1/month means once a month,
1/3 means once January -March, once April -June, once July -September, and once
October -December, 1/6 months means once January -June and once July -December
of each year.
*5. Detection limits for each parameter shall be at least as low as outlined in the chart.
9

PART I.
EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
C. Monitoring and Reporting
1. Representative Sampling
IU Name: DAK Americas, 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 on or before the tenth of the month following sample
collection. The PWC may require more frequent monitoring, or the monitoring of
additional pollutants not required in this permit, by written notification.
If the sampling performed by the permittee indicates a violation, the permittee shall
notify the PWC within 24 hours of becoming aware of the violation. The permittee
shall also repeat the sampling and analysis and submit the results of the repeat
analysis to the PWC within 30 days after becoming aware of the violation.
3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with
the techniques prescribed in 40 CFR Part 136 (U.S. Environmental Protection
Agency), and amendments thereto unless specified otherwise in the monitoring
conditions of this permit.
4. Certified Laboratory Analysis
Pollutant analysis shall be performed by a North Carolina Department of
Environmental and Natural Resources Certified Laboratory that is certified in the
analysis of the particular pollutant in wastewater.
10

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

ni
PART H. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
Part II. GENERAL PERMIT CONDITIONS
A. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit non-
compliance constitutes a violation of the City of Fayetteville Sewer Use Ordinance
and is grounds for possible enforcement action(s).
B. Duty to Mitigate - Prevention of Adverse Impact
The permittee must take all reasonable steps to minimize or prevent any discharge
in violation of this permit which has a reasonable likelihood of adversely affecting
human health, the POTW's discharge, the water receiving the POTW's discharge, or
the environment.
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 Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
E. Upset Conditions
An "upset" means an exceptional incident in which there is an. unintentional and
temporary non-compliance with the effluent limitations of this permit because of
factors beyond the reasonable control of the permittee. An upset does not include
non-compliance to the extent caused by operational error, improperly designed or
inadequate treatment facilities, lack of preventative maintenance, or careless and/or
improper operations.
An upset may constitute an affirmative defense for actions brought for the non-
compliance. The permittee has the burden of proof 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 Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
Except for data determined to be confidential under the City of Fayetteville's Sewer
Use Ordinance, Division 7, all reports prepared in accordance with terms of this
permit shall be available for public inspection through the office of the Public Works
Commission of the City of Fayetteville. As required by the Sewer Use Ordinance,
effluent data shall not be considered confidential.
H. Duty to Provide Information
The permittee shall furnish to the Manager of the Public Works Commission or his
designee, or the Division of Environmental Management, within a reasonable time,
any information which the above parties may request to determine whether cause
exists for modifying, revoking and re -issuing, or terminating this permit or to
determine its compliance with this permit. The permittee shall also furnish, upon
request, copies of records to be kept by this permit.
I. Signatory Requirements
All reports or information submitted pursuant to the requirements of this permit
must be signed and certified by the Authorized Representative as defined under
the Sewer Use Ordinance. If the designation of an Authorized Representative is
no longer accurate because a different individual or position has responsibility for
the overall operation of the facility, or overall responsibility for environmental
matters for the company, a new authorization satisfying the requirements of this
section must be submitted to the PWC System Protection Supervisor prior to or
together with any reports to be signed by an authorized representative.
J. Toxic Pollutants
If a toxic effluent standard or prohibition (including any schedule of compliance
specified in such effluent standard or prohibition) is established under Section 307(a)
of the Federal Clean Water Act for a toxic pollutant which is present in the discharge,
and such standard or prohibition is more stringent than any limitation for such
pollutant in this permit, this permit may be revised or modified in accordance with
the toxic effluent standard or prohibition and the permittee so notified.
K. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or
criminal penalties for non-compliance.
14

PART II. IU Name: DAK Americas, LLC
GENERAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 01
40 CFR#: 414
L. Federal and/or State Laws
Nothing in this permit shall' be construed to preclude the institution of any legal
action or relieve the permittee from any responsibilities, liabilities, or penalties
established pursuant to any applicable Federal and/or State Laws or regulations.
M. Penalties for Violation of Permit Conditions
The City of Fayetteville Sewer Use Ordinance provides that any person who violates
a permit condition is subject to a civil penalty not to exceed $25,000.00 per day of
such violation, with each day deemed as a separate violation.
N. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in any enforcement action that it would have
been necessary to halt or reduce the permitted activity to maintain compliance with
the conditions of this permit.
O. Penalties for Falsification of Reports
The City of Fayetteville Sewer Use Ordinance and North Carolina General Statute
143-215 provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required
to be maintained under this permit, including monitoring reports or reports of
compliance or non-compliance shall, upon conviction, be punished by a fine, or by
imprisonment for not 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.
15

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

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

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

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

PART III. IU Name: DAK Americas, LLC
SPECIAL PERMIT Permit#: 2116RF
CONDITIONS Pipe#: 41
40 CFR#: 414
PART III. SPECIAL PERMIT CONDITIONS
A. Biotoxicity Monitoring
If it is found that the permittee's effluent has a significant toxic impact upon the
municipal wastewater treatment system and/or its receiving stream, the permittee
shall be required, upon written notification from the PWC, to conduct Biotoxicity
monitoring on the effluent being discharged. The severity of the permittee's effluent
toxicity shall determine the frequency of the Biotoxicity monitoring.
B. Toxicity Control
Upon determination of toxicity in the permittee's effluent, the permittee shall be
required to identify and eliminate the source(s) of the toxicity from the final
discharge.
C. Flow Monitoring
The permittee shall record and report (to PWC) daily wastewater discharge flows
from this facility. Flow data shall be recorded from the first of the month to the last
day of the month and submitted to PWC by the tenth of the following month.
Where flow monitoring is required by PWC the equipment must meet current PWC
flow meter specifications. The installed flow meter shall be calibrated once January -
June and once July -December and documentation of the calibration event shall be
submitted to PWC. Additional calibrations shall be performed by the Permittee, at
the request of PWC, in the event of significant questions concerning the accuracy of
the meter, including but not limited to:
1. Increase or decrease in sewer flow greater than twenty-five percent (25%) in
two consecutive months.
2. Increase or decrease in "sewer flow to water consumption" ration above ten
percent (10%) in two consecutive months.
PWC shall be notified within twenty-four (24) hours of any malfunction, damage, or
repairs to the flow meter. PWC reserves the right to revert to billing for sewer based
on water consumption in the event of the failure of the permittee's flow meter to
perform properly; or the failure of the permittee to submit the required data and
documentation to PWC in a timely fashion: The permittee must contact PWC for
current flow meter specifications prior replacing a flow meter for any reason.
20

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

PART IV.
PERMIT SYNOPSIS
City of Fayetteville, North Carolina
Public Works Commission
Industrial Pretreatment Program Permit
PART IV. IUP Synopsis
A. IUP Basic Information
IU Name: DAK Americas, LLC
Permit#: 2116RF
Pipe#: 01
40 CFR#: 414
Receiving POTW name:
Rockfish Creek Water Reclamation Facility
POTW NPDES#:
NC0050105
IUP Name:
DAK Americas LLC
IUP Effective Date:
Effective Date of this Permit
IUP Expiration Date:
Expiration Date of this Permit
B. IU Survey & Application form
Attached is a completed copy of the Industrial User Wastewater Survey &
Application Form.
C. IU Inspection form
Attached is a copy of the most recent Industrial User Inspection.D. RATIONALE
FOR LIMITATIONS:
as listed on the IUP Limits Page(s), PART I, Section B of the IUP.
PIPE 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
22

POTW=>
NPDES#a>
IUP
Count
2
3
4
5
6
7
8
9
10
Workbook Name : Rockfish HWA.AT final July 2008, Worksheet Name: AT
Printed: 5/22/2009, 10:43 AM
Page 1 of 3
Allocation Table
Spreadsheet Instructions:
. Headworks last approved:
07/03/08
1) Applicable Values should be entered in the Heavy Bordered cells. Rest of worksheet is protected, password is
Allocation Table updated:
01/01/09
,
2) Formulas are discussed in the Comprehensive Guidance, Chapter 6, Section C.
Permits last modified:
3) HWA and AT worksheets in this workbook are linked. Pollutant Names, MAHLs, Basis, and Uncontrollable load
in this AT from the HWA spreadsheet. This includes names in
worksheet are automatically entered pollutant
columns AT through BK.
Rockfish Creek
NC0050105
Industry
Type Renewal Modification Date
FLOW
Permit Limits
CBOD
Permit Limits
TSS
Permit Limits
Ammonia
Permit Limits
INDUSTRY NAMES Permit
(please list atphabeticIy) number
Pipe of Effective Effective Permit
number Indus Date Date Ex ires
MGD al/da
Conc. Load
m lbs/da
Conc. Load
m lbs/da
Conc. Load
m 1 lbs/da
DAK
2116RF
. 0001
414
01/01/09
04/01/09
12/31/13
0.0750
75,000
25.00
15.64
25.00
15.64
monitor
Eaton Corporation
2111 RF
0001
433
01/01/09
12/31/13
0.0500
50,000
monitor
monitor
monitor
MJ Soffe LLC
2113RF
0001
410
01/01/09
02/01/09
12/31/13
0.7000
700,000
200.00'
1167.60
200.00
1167.60
monitor
Nitta Gelatin
2117RF
0001
311999
01/01/09
12/31/13
0.1850
185,000
1275.00
1967.20
750.00
1157.18
50.00
77.15
Column Totals =>
1 1.0100
1,010,0001
3150
2340
1 771
Basis=>
MAHL from HWA (lbs/day) =>
Uncontrollable Loading (lbs/day) _>
Total Allowable for Industry (MAIL) (lbs/day) =>
Total Permitted to Industry (lbs/day) _>
MAIL left (lbs/day) _>
Percent Allow. Ind. (MAIL) still available (%)=>
Percent MAHL still available (%)=>
5 Percent MAHL (lbs/day) =>
HWA.AT
Revised:November 2005
NPDES
NPDES Permitted Flow=> 21.0000
12.1679
8.8321
1.0100
7.8221
88.6 %
37.2 %
1.0500
Design
30737
12891
17846
3150
14696
82.3 %
47.8 %
1537
Design
46500
22896
23604
2340
21263
90.1 %
45.7%
2325
NPDES
7228.48
2187.07
5041.41
77.15
4964.26
98.5 %
68.7%
361.42

64\ To .old-` %K flptk� `k
(MA/ c k+1-- fo - Pt())/sa "ry
(Oa (li«
Cc) lfz- poaR S F Q
'7 C. bTe
GOC)(_<- (1 ,_ (..ko e(wf
C op
(--(-)i 257'
/-2&-b F-Lb, 6-14
A-06--as
NtivS�(c�
Luc c L

MEMO — Note to file RE: DAK Americas LLC — Cedar Creek Site
NPDES Permit NC0003719
Joe Corporon / 20May09
DWQ's Response /Summary of Permittee Comments on the Draft Permit (received
08May09)
• [cover letter] DWQ's EAA Review / Decision not to renew the permit
DAK feels that cost to divert 100% discharge to PWC will approximate
$400K/year and that this is significant, despite our 15% alternative comparison. They
wish to maintain both discharge options - SS and discharge to the Cape Fear. Moreover,
they intend to revise the EAA and resubmit before the draft -review deadline on May 27,
2009. They ask us to remove Special Condition A. (5.), our requirement to abandon all
discharge to the Cape Fear River and our intent to deny renewal at expiration.
• Denied — DWQ will reissue the NPDES permit, except as revised below.
DAK's Additional Numbered Comments:
1) Revised flow — DAK feels that DWQ did not consider additional flow allocated
for the Recycling facility nor did we allow sufficiently for future expansion. They
wish to keep the plant classification Grade III and the previous flow of 0.500
MGD (0.228 plus 0.111 = 0.339 MGD plus 0.161 MGD room to expand).
• Granted [note: @ 0.500 MGD IWC = 0.09 %]
2) Limit Calculations — DAK requests that DWQ recalculate permit limits using a
revised long-term average flow to better reflect 2005-2008 data, and include flow
for the proposed recycle facility (again, 0.111 + 0.228 = 0.339 MGD).
• Granted — DWQ will apply this flow to §414.41 and §414.91 9b.
3) TRC - no issues
4) Stormwater Outfalls — DAK wishes to consolidate all stormwater outfalls to lift
their administrative burden.
• Denied — DWQ will reissue the existing NC00 permit and the existing
NCS00 stormwater permit to include all1utfalls. (?)
s`C-o‘tRW5) Proposed Recycle facility — Flow calculation issue (see 2); Although not regulated
by 40 CFR under SIC code 5162, DAK requests DWQ to include their flow
estimate of 0.111 MGD in the flow, limits, and monitoring calculations assume
effluent characteristics regulated under OCPSF §414.41 and §414.91 9b.
• Granted U 9 v <ill 6

Gorporon, Joe
qt-k- R(t-) P bP
(
From: [e-mail]
Sent: Wednesday, May 06, 2009 2:59 PM
To: [e-mail]
Subject: NC0003719, DAK Americas LLC
EPA has no comments on this draft permit.
1

AFFIDAVIT OF PUBLICATION
NORTH CAROLINA
Cumberland County
Public Notice
North Carolina Emironmen -
tal Management
Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to issue a
NPDES Wastewater Permit
The North Carolina Environ -
mental Management Com -
mission proposes to Issue a
NPDES wastewater dis-
charge permit to the
person(s) listed below.
Written comments regarding
the proposed permit will be
accepted until 30 days after
the publish date of this no-
tice. The Director of the NC
Division of Watcr Quality
(DWQ) may hold a public
bearing should there be a
significant degree of public
Interest Please mall com -
ments and/or information re-
quests to DWQ at the above
address. Interested persons
may visit the DWQ at 512 N.
Salisbury Street. Raleigh. NC
to review information on file.
Additional information on
NPDES permits and this no-
tice may be found on our
website: www.ncwaterquali -
tyorg, or by calling (919)
807-6304.
The NC Department of Cor-
rection 14216 Mail Service
center, Raleigh, NC 27699-
4216] has applied for renew -
al of NPDES permit
NC0035904 for the McCain
Hospital WWTP in Hoke
County. This peuniued facili-
ty discharges treated waste -
water to an unnamed uibuta -
zy to Mountain Creek in the
Lumber River Basin. Cur-
rently fecal coliform and to-
tal residual chlorine are wa-
ter quality limited. This dis-
charge may affect future al-
locations in this portion of
the Lumber River basin.
DAK Americas LLC - Ccdar
Creek Site (NC0003719) re-
quested renewal of its per-
mit in Cumberland County;
this facility discharges treat -
ed wastewater to the Cape
Fear River wfin the Cape
Fear River Basin.
The Town of Lake
Waccamaw WWTP request -
ed renewal of permit
NC0021881 for Lake
Waccamaw WWTP in Co-
lumbus County; this permit -
ted discharge is treated
wastewater to and unnamed
tributary of Bogue Swamp,
Lumber River Basin.
Notice of Intent to Issue a
NPDES Wastewater Permit
1218395
Before the undersigned, a Notary Public of said County and state, duly
commissioned and authorized to administer oaths, affirmations, etc.,
personally appeared. CINDY L. OROZCO
Who, being duly sworn or affirmed, according to law, doth depose and say
that he/she is LEGAL SECRETARY
of THE FAYETTEVILLE PUBLISHING COMPANY, a corporation organized
and doing business under the Laws of the State of North Carolina, and
publishing a newspaper known as the FAYETTEVILLE OBSERVER, in the
City of Fayetteville, County and State aforesaid, and that as such he/she
makes this affidavit; that he/she is familiar with the books, files and
business of said Corporation and by reference to the files of said publication
the attached advertisement of CL Legal Line
PUBLIC NOTICE NC ENVIRONMENTAL
of NC DIVISION OF WATER QUALITY
was inserted in the aforesaid newspaper in space, and on dates as follows:
4/24/2009
and at the time of such publication The Fayetteville Observer was a
newspaper meeting all the requirements and qualifications prescribed by
Sec. No. 1-597 G.S. of N.C.
The above is correctly copied from the books and files of the aforesaid
corporation and publication.
LEGAL SECRETARY
Title
Cumberland County, North Carolina
Sworn or affirmed to, and subscribed before me, this 24 day
of April, A.D., 2009.
In Testimony Whereof, I have hereunto set my hand and affixed my
official seal, the day and year
aforesaid.
YYD2,12_
Pamela H. Walters, Notary Public
My commission expires 05th day of December, 2010.
MAIL TO: NC DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699
0001218395

Permit Number NC0003719
Central Files: APS SWP
04/06/09
Permit Tracking Slip
Program Category
NPDES WW
Permit Type
Industrial Process & Commercial Wastewater Discharge
Primary Reviewer
joe.corporon
Permitted Flow
1250000
Facility
Facility Name
Cedar Creek Site
Location Address
3468 Cedar Creek Rd
Fayetteville NC 28301
GrX L-E ci '9(e
Owner
Status
In review
Project Type
Renewal
Version Permit Classification
Individual
Permit Contact Affiliation
Major/Minor
Major
Region
Fayetteville
County
Cumberland
Facility Contact Affiliation
Anthony
PO Box 1690
Fayetteville
Hudson, Manager
Safety -Environmental
NC 28302
Owner Name
DAK Americas, LLC
c,Fst": '1t&— "S i-4}47g
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Craig
PO Box 1690
Fayetteville
Leite
NC
28302
Orig Issue App Received
02/23/81 05/03/06
Regulated Activities
Draft Initiated
Domestic, other
Inorganic chemical manufacturing
Non -contact cooling water, condensate
Pesticide and herbicide production
Outfall 001
Scheduled
Issuance
Public Notice Issue Effective
Requested/Received Events
Engineer/tech specialist certification requested
Region comments on draft requested
Region comments on draft received
RO staff report received
RO staff report requested
Engineer/tech specialist certification received
Expiration
Waterbody Name
CAPE FEAR RIVER
Stream Index Number
18-(26)
Ciu:k 5aA
Current Class
C
Subbasin
03-06-15

DENR / DWQ / NPDES Program, Joe R. Corporon, NPDES East
FACT SHEET FOR NPDES Permit Renewal
Permit NC0003719
INTRODUCTION
DAK Americas, LLC - Cedar Creek Site (herein referred to as DAK or the Permittee) requires a National
Pollutant Discharge Elimination System (NPDES) permit to discharge treated wastewater to the surface
waters of the state. The permittee's 5-year permit has expired and they have requested renewal from the
Division of Water Quality (the Division or DWQ). This Fact Sheet summarizes background information and
rationale used by the Division's NPDES Program to determine permit limits and monitoring conditions.
FACILITY RECORDS REVIEW
Facility Description. DAK Americas, LLC (Table 1) treats wastes from their manufacture of polyester resin
chips and also from neighboring DuPont Teijin Films (both OCPSF regulated). A Service Complex provides
utilities to both DAK and to DuPont including steam, cooling water, chilled water, demineralized water, and
wastewater treatment. The Service Complex also treats local domestic wastes from plant personnel.
Wastewater treatment facilities consists of flow equalization, spill basin, pH adjustment, oil skimming,
comminutor, dual aeration basins, clarifier, parshall flume, sludge pump station, dual aerobic digesters,
aerated biosolids holding basin, biosolids drying beds, and other associated equipment. With a decrease in
flow from 0.500 to 0.300 MGD, this plant will be downgraded from a Grade III to Grade II WWTP.
While maintaining its surface -water discharge, DAK connected to Fayetteville's sewer -collection system
on May 1, 2006 with average flow — 0.030 MGD to the Fayetteville Public Works Commission (PWC).
Facility Information
Applicant/Facility Name:
DAK Americas, LLC — Cedar Creek Site .
Applicant Address:
P.O. Box 1690, Fayetteville, North Carolina 28302
Facility Address:
3468 Cedar Creek Road; Fayetteville, North Carolina 28301
Permitted Flow
0.300 MGD
Type of Waste:
OCPSF Outfall 002 (95% industrial, 5% domestic) SIC 1,2n I
Facility/Permit Status:
Grade II / Active; Renewal zt vf. /6 2 {'
County:
Cumberland County
Miscellaneous
Receiving Stream:
Cape Fear River
Regional Office:
Fayetteville
Stream Classification:
C
State Grid /
USGS Quad:
H23NE /
Cedar Creek, NC
303(d) Listed?
No
Permit Writer:
Joe Corporon
Subbasin:
03-06-15
Date:
10Mar09
Drainage Area (mi2):
4395
• -'�
4z
Lat. 34° 58N1" N Long. 78° 47' 00" W
Summer 7Q10 (cfs)
791
Winter 7Q10 (cfs):
30Q2 (cfs)
Average Flow (cfs):
4340
IWC (%):
0.06%
FINAL Fact Sheet
Renewal -- NPDES Permit NC0002305
Page 1
l

1
PERMIT HISTORY AND CORRESPONDENCE
Previous Permit and Waste Load Allocation (WLA) -- Division WLA records for this facility date
previous Permittees from 1985. The previous permit (effective Jun 7, 2004 / expired Oct 31, 2006) included
a special condition providing detailed requirements for DAK's closure of the Monsanto facilities.
The Permittee's Renewal Application — With this renewal, DAK has requested the Division to consider
the discharge requirements for a proposed new OCPSF-regulated plastic bottle recycle plant. DAK
anticipates applying for permit Authorization to Construct from DWQ's Construction Grants and Loans.
Closure of the Monsanto Plant — Previous Permittee, the Monsanto Company's Fayetteville Facility,
produced Roundup®, a glyphosate-based pesticide/herbicide. This facility was formally closed and
demolished to the satisfaction of the Division, as specified in the permit modification, effective June 7,
2004. Accordingly, this renewal is no longer concerned with Monsanto -related chemicals in the discharge
(see Permitting Strategy). Moreover, Monsanto negotiated with Fayetteville's PWC to connect to the city's
sanitary sewer system and Fayetteville ran a city sewer line to this property.
Special Condition, A.(5.) to the previous permit addressed this newly completed sewer line, the closure of
the Monsanto plant, and the change -of -ownership in progress. This special condition required any new
owner/renewal applicant to justify flow needs and to .provide an Engineering Alternatives Analysis (EAA)
to justify continuing discharge to surface waters.
DAK's Engineering Alternatives Analysis (EAA) History -- Since assuming ownership of the facility,
DAK has continued to discharge under this permit, but also discharges approximately 0.030 MGD to the
city sewer (connected under PWC's Pretreatment Program on May 1, 2006).
Subsequent to notifying change -of -ownership, DAK submitted a flow justification and EAA to evaluate
discharge alternatives (received August 30, 2004) in accord with previous permit Special Condition A.(5.).
The Division was dissatisfied with this EAA, requested clarification and additional information (letter of
October 21, 2004), and DAK responded on December 8, 2004.
After additional review and correspondence, the Division again requested clarification, and DAK provided
a revised flow summary and new present -value costs for viable discharge alternatives (see Permittee's letter
received March 5, 2008). In this document, DAK concluded that they prefer (based on cost) to discontinue
their active discharge to the city sewer and to continue surface -water discharge under the NPDES permit.
Despite Division urgings, DAK will not request to rescind this permit, and has again requested renewal.
(For renewal decisions, and justification for DWQ's intent not to renew this permit, see Permitting
Strategy).
Total Residual Chlorine (TRC) and Whole Effluent Toxicity (WET) Testing. Considering that DAK's
discharge constitutes less than one percent of the receiving stream (IWC 0.06% at 0.300 MGD), DAK
conducts acute WET testing to evaluate acute, end -of -pipe impacts to the receiving stream. This is
consistent with facilities statewide with an IWC less than 0.25%. The DAK facility has passed WET test
consistently for the past 21 Quarters with one failure in May, 2003.TRC limit has also been added to the
permit (28 ug/L), consistent with the new statewide standard for chlorine. However, TRC values detected
below 50 ug/L will be considered compliant with the permit [see permit, Part 1. (A.), TRC footnote].
Fact Sheet for Pennit Renewal - 2009
NPDES NC0003719
Page 2

PERMITTING APPROACH
Decision to Revoke This Permit — the Division intends to renew this permit, but for two years only. It
will expire in accord with the Cape Fear basinwide renewal schedule on October 31, 2011. The Division
will not consider further application to renew.
The Division notes that the Permittee's latest present -value costs for viable discharge alternatives range
within 12.8% considering, a) remaining connected to the city sewer, or b) continuing discharge to the Cape
Fear River. Historically, the Division has considered EAA discharge -alternative costs equally viable if
within 15%. Considering the Division's directive under the NPDES Program to regionalize wastewater
treatment statewide, the Division disagrees with the Permittee's choice to abandon its city sewer
connection, and continue discharge to the Cape Fear River.
In support of this decision, state and federal statutes provide grounds and guidance to revoke a permit:
§40 CFR 122.64(a) (4) "The following are causes for terminating a permit during its term,
or for denying a permit renewal application: ... (4) A change in any condition that requires
either a temporary or permanent reduction or elimination of any discharge or sludge use or
disposal practice controlled by the permit (for example, plant closure or termination of
discharge by connection to a POTW)." and,
§15A NCAC 02H .0104(a)(3) "(a) Any permit issued pursuant to this Section is subject
to revocation or modification in whole or part pursuant to 40 CFR 122.62 or for any of
the following: ... (3) a change in any condition that requires either a temporary or
permanent reduction or limitation of the permitted discharge"
In light of DWQ's mission to eliminate point -source discharges in support of its Long Term Management
Plan (LTMP) or Pretreatment Program, we will allow this permit to expire and formally close and abandon
facilities discharging to the Cape Fear River. Upon expiration, 100 % of this discharge will be conveyed to
the Fayetteville PWC for wastewater treatment under its existing Pre -Treatment Program permit [see
renewal Special Condition A. (5.)]. This information will be outlined in the renewal cover letter.
Flow Limit and Instream Waste Concentration (IWC) Revised for Renewal — DAK has provided
revised flow estimates, (see DAK's letter received March 5, 2009), and the Division understands that this
facility now generates less wastewater at Outfall 002; flows averaging 0.175 MGD (range 0.131 to 0.243
MGD). Based on these new data, the Division will lower permit flow limit for final Outfall 002 from the
previous 0.500 MGD to 0.300 MGD to comfortably accommodate the flow range. This revises the instream
waste concentration (IWC) from the previous 0.24% to 0.06% of the receiving stream (based on a summer
7Q10 of 791 cfs). With a decrease in permitted flow from 0.500 to 0.300 MGD, this plant has been
downgraded from a Grade III to Grade II WWTP — parameter monitoring frequencies have been adjusted
accordingly.
Verifying Existing Stream Conditions — this facility discharges to the Cape Fear River [18-(26)], a Class
C waterbody, extending from the City of Fayetteville's water -supply intake to the mouth of Hammond
Creek, within the Cape Fear River Basin.
Fact Sheet for Permit Renewal - 2009
NPDES NC0003719
Page 3

i
Renewal Staff Report -- Pending a final technical review, the FRO recommends renewal of this
permit in accordance with the Basin Plan and comments presented herein.
Compliance Review - Notices of Violation (NOVs). This facility received BOD limit violations in
February of 2004, but has since has received no permit limit violations and no assessed penalties for 58
consecutive months (March 2004 through December 2008).
Stormwater Outfalls — DAK has requested that this renewal combine under a single permit, their effluent
discharge with their existing stormwater outfalls (see stormwater permit NCS000389). In light of the
Division's decision not to renew this permit, this request is hereby denied.
Federal Regulations Applicable to Renewal — With the DWQ-approved abandonment of discharges from
Monsanto (former Permittee) during the previous permit cycle, this renewal hereby discontinues any
reference to categorical regulations concerning pesticides/herbicides. In accord with the Permittee's
application to renew, the Division applied the following regulations for Organic Chemicals, Plastics and
Synthetic Fibers (OCPSF) for this renewal:
• §40 CFR 414.40, Subpart D, 414.41 Best Available Technology (BAT) for
Thermoplastic Resins, and
• §414.91 (b), Subpart I for Direct Discharge Point Sources That Use End -of -Pipe
Biological Treatment.
§40 CFR 414.40, Subpart D — The Division applied multipliers for the parameters BOD5 and TSS, as
required under OCPSF 414.40, Subpart D. Based on production, Section §414.41 BAT is appropriate
because DAK's previous and projected OCPSF volume exceeds five million pounds per year (310.25
million pounds projected for 2009), as outlined in the renewal application received December 11, 2008.
In keeping with EPA Region 4 guidance, DWQ used the actual reported long-term average flow (60
months from January 2005 through December 2008) of 0.199 MGD to calculate both Daily Maximum
and Monthly Average permit limits for BOD5 and TSS (Table 2).
Table 2.
Parameter Limit Calculations
Subpart D
in MGD)
Previous
(lbs./day)
Daily
Maximum
Limits
Monthly
Average
Renewal
(lbs./day)
Daily
Maximum
Limits
Monthly
Average
15.45
§40 CFR 414.40,
(Flow
Parameter
For Daily
Maximum
For Monthly
Average
BOD, 5-day
64 x 0.1991
24 x 0.1991
115.7
43.5
21.11
TSS
130 x 0.1991
40 x 0.199 I
235.7
72.5
215.76
66.39
pH
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
1 The Division used the 4-year average flow of 0.200 MGD (Jan 2005 — Dec 2008) for both Daily Maximum
and Monthly Average limits, as recommended by EPA.
Application of §40 CFR 414.91, Subpart I — This subpart requires the Permittee to monitor a list of 57
organic compounds, and 6 toxicants [including metals and cyanide; for toxicants limit calculations, see
Metals and Toxicants - Reasonable Potential Analysis (RPA)]. As dictated by this subpart, permit limits for
each of these 57 compounds were determined by a multiplier (in gg/L) times the process wastewater flow.
Again, the Division used the average flow of 0.199 MGD.
Fact Sheet for Permit Renewal - 2009
NPDES NC0003719
Page 4

Each parameter's resultant limit was- further evaluated against existing state and federal standards to fmd the
more stringent (see attached XL spread sheet, Limit Calculations for 40CFR, Subpart I, 414.90 and 91).
Final values appear in the permit as mass limits not to exceed in lbs/day. The previous permit renewal
relaxed monitoring frequencies to 1/Year for organics and 1/Quarter for metals and cyanide. Based on
minimum or no detection of these parameters during the past permit cycle, the Division considers these
limits and monitoring conditions appropriate for this renewal.
Concerning Ammonia (NH3 as N) and Chemical Oxygen Demand (COD) — Previously permitted
parameter COD - maximum reported 413 lbs/day, was not permit -limited at a flow rate of 0.500 MGD, and
was monitored 1/Week. The Division recommends no changes to the permit for COD. Ammonia (NH3)
limits were adjusted proportionally to the revised effluent flow (0.500 to 0.300 MGD) by multiplying 0.6
times the previous Daily Maximum and Monthly Average limits.
Metals and Toxicants - Reasonable Potential Analysis (RPA). Based on the previous permit, the
parameters of concern include Total Copper, Total Chromium, Total Cyanide, Total Lead, Total Nickel, and
Total Zinc. The Division conducted an RPA to determine the "reasonable potential" for a given toxicant to
exceed its water -quality standards or criteria. The RPA evaluated on 60 months of data (12 to 15 samples
collected quarterly) during the period January 2005 through December 2008. At an IWC of 0.06%, none of
these parameters show reasonable potential to exceed water -quality standards. [These metals require limits
under 40 CFR despite RPA findings]
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
NPDES UNIT e TAC
If you have questions reg • din y f'the above information or on the attached permit, please contact Joe
Corporon at (9195 807-6
April 22, 2009.
June 30, 2009
NAME:
DATE: a7-1fae6cf
Fact Sheet for Permit Renewal - 2009
NPDES NC0003719
Page 5

DAK Americas, LLC - Fayettevi
NC0003719
0.2 MGD
0.30 MGD
no
791 cfs
4,340 cfs
OCPSF Subpart !Calculations
Joe Corporon, NPDES East, 26Mar09
[OCPSF flow adjusted from previous 0.2179 MGD to 0.20 MGD, in accord with the renewal application j
le, NC
Parame
."
Acenaphthene
Acenaphthylene
Acrylonitrile
Anthracite
Benzene
Benzo(a)anthracene
3.4-Benzofluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Bis(2-ethylhexyl) phthalate
Carbon Tetrachloride
Chlorobenzene
Chloroethane
Chloroform
2-Chlorophenol
Chrysene
Di-n-butyl phthalate
1.2-Dichlorobenzene
13-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
1,2-trans-Dichloroethylene
2,4-Dichlorophenol
1.2-Dichloropropane
1,3-Dichloropropylene
Diethyl phthalate
2,4-Dimethylphenol
Dimethyl phthalate
4.6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Ethylbenzene
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Methyl Chloride
Methylene Chloride
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
Phenanthrene
Phenol
OCPSF
• - Daily:
59 22 0.098 0.037 FC
59 22 0.098 0.037 FC
242 96 0.402 0.159 FC
59 22 0.098 0.037 FC
136 37 0.226 0.061 SS
59 22 0.098 0.037 FC
61 23 0.101 0.038 FC
59 22 0.098 0.037 FC
61 23 0.101 0.038 FC
279 103 0.463 0.171 FC
38 18 0.063 0.030 SS
28 15 0.046 0.025 FC
268 104 0.445 0.173 FC
46 21 0.076 0.035 SS
98 31 0.163 0.051 FC
59 22 0.098 0.037 FC
57 27 0.095 0.045 FC
163 77 0.271 0.128 PC
44 31 0.073 0.051 it
28 15 0.046 0.025 FC
59 22 0.098 0.037 FC
211 68 0.350 0.113 FC
25 16 0.041 0.027 FC
54 21 0.090 0.035 FC
112 39 0.186 0.065 FC
230 153 0.382 0.254 FC
44 29 0.073 0.048 FC
203 81 0.337 0.134 FC
36 18 0.060 0.030 SS
47 19 0.078 0.032 FC
277 78 0.460 0.129 FC
123 71 0.204 0.118 FC
285 113 0.473 0.188 FC
641 255 1.064 0.423 FC
108 32 0.179 0.053 FC
68 25 0.113 0.041 PC
59 22 0.098 0.037 FC
28 15 0.046 0.025 FC
49 20 0.081 0.033 SS
54 21 0.090 0.035 PC
190 86 0.315 0.143 PC •
89 40 0.148 0.066 FC
59 22 0.098 0.037 FC
68 27 0.113 0.045 PC
69 41 0.115 0.068 FC
124 72 0.206 0.119 PC
59 22 0.098 0.037 FC
26 15 0.043 0.025 FC
2
3
4
Limit Calculations per 40 CFR, Subpart I - 414.90 and 91
(Comparisons to state standards and criteria)
* Standards and Criteria Updated, 27Mar2009 - changes to previous permit in blue
5
Standards and Criteria
6 7 8
9
10
j+t�`. FederaIi Y
c'tat� err
Se
'`Standard
Standard'..:
• ^Aquatic 1.
water •.
t Standard' Q e
60 None 20
none none none
none 0.25 0.051
0.05 40000 ' 9600
none 51 1.19
none 0.0311 0.0028
none 0.0311 0.0028
none 0.0311 0.0028
none 0.0311 0.0028
none 2.2 1.2
none 1.6 0.254
130 none 140
none none note
none 170 5.6
none 400 0.1
none 0.018 none
9.5 none none
470 17000 2700
390 2600 400
100 2600 400
20000 170000 6700
none 37 0.38
none 7100 330
none 10000 140
none none none
none 15 0.5
none 21 0.31
1200 none none
320 none none
3400 none none
none 765 13.4
26 none none
none 3.4 0.11
none 0.048 0.71
97 none none
0.11 none none
46 none none
none 0.00028 0.00029
none 18 0.44
none 3.3 1.4
none 96 2.6
none 590 4.6
330 none none
none 30 17
8000 none none
750 none 270
none none none
none 300 300
4/15/2009
C6 cl nO�l�
ee
no
no
Yes
no
Yes
yes
yes
yes
Yes
yes
yes
no
no
yes
no
yes
no
no
no
no
no
yes
yes
no
no
no
no
no
no
no
no
no
yes
no
no
no
no
yes
yes
yes
no
Yes
no
no
no
no
no
no
60
none
0.25
0.05
51.00
0.03
0.03
0.03
0.03
2.20
1.6
130
none
170
400
0.018
10
470
390
100
20,000
37
7,100
10,000
none
15
21
1,200
320
3,400
765
11
j.Watet Qua1.
z_=_ Iba/dy
12
13
255.52 0.098 0.098
none 0.098 0.098
5.84 0.402 0.402
0.21 0.098 0.098
1191 0.226 0.226
0.73 0.098 0.098
0.73 0.101 0.101
0.73 0.098 0.098
0.73 0.101 0.101
51.38 0.463 0.463
37.37 0.063 0.063
554 0.046 0.046
none 0.445 0.445
3970 0.076 0.076
1703 0.163 0.163
0.42 0.098 0.098
40.46 0.095 0.095
2002 0.271 0.271
1661 0.073 0.073
426 0.046 0.046
85,172 0.098 0.098
864 0.350 0.350
14
15
OCPSF 0.098
OCPSF 0.098
OCPSF 0.402
OCPSF 0.098
OCPSF 0.226
OCPSF 0.098
OCPSF 0.101
OCPSF 0.098
OCPSF 0.101
OCPSF 0.463
OCPSF 0.063
OCPSF 0.046
OCPSF , 0.445
OCPSF 0.076
OCPSF 0.163
OCPSF 0.098
OCPSF 0.095
OCPSF 0.271
OCPSF 0.073
OCPSF 0.046
OCPSF 0.098
OCPSF 0.350
165,817 0.041 0.041 OCPSF 0.041
42,586 0.090 0.090 OCPSF 0.090
none 0.186 0.186 OCPSF 0.186
64 0.382 0.382 OCPSF 0.382
89 0.073 0.073 OCPSF 0.073
5,110 0.337 0.337 OCPSF 0.337
1,363 0.060 0.060 OCPSF 0.060
14,479 0.078 0.078 OCPSF 0.078
3,258 0.460 0.460 OCPSF 0.460
26 111 0.204 0.204 OCPSF 0.204
3.4 79 0.473 0.473 OCPSF 0.473
0.048 0.20 1.064 0.204 WQ Standard 81.7
97 413 0.179 0.179 OCPSF 0.179
0.11 0.47 0.113 0.113 OCPSF 0.113
46 196 0.098 0.098 OCPSF 0.098
0.0003 0.007 0.046 0.007 WQ Standard 2.6
18.0 420 0.081 0.081 OCPSF 0.081
3.3 77 0.090 0.090 OCPSF 0.090
96 409 0.315 0.315 OCPSF 0.315
590 13.779 0.148 0.148 OCPSF 0.148
330 1,405 0.098 0.098 OCPSF . 0.098
30 128 0.113 0.113 OCPSF 0.113
8,000 34,069 0.115 0.115 OCPSF 0.115
750 3.194 0.206 0.206 OCPSF 0.206
none none 0.098 0.098 OCPSF 0.098
300 1,278 0.043 0.043 OCPSF 0.043
16
,
bits;'
r•
17
Monthly, •
It
.lbs/day
lbs/day 0.037
lbs/day 0.037
Ibs/day 0.159
lbs/day 0.037
lbs/day 0.061
Ibs/day 0.037
1bs/day . 0.038
Ibs/day 0.037
Ibs/day 0.038
lbs/day 0.171
lbs/day Q.030
Ibs/day 0.025
lbs/day 0.173
lbs/day 0.035
lbs/day 0.051
Ibs/day 0.037
lbs/day 0.045
lbs/day 0.128
lbs/day 0.051
Ibs/day 0.025
lbs/day 0.037
lbs/day 0.113
lbs/day 0.027
lbs/day 0.035
lbs/day 0.065
lbs/day 0.254
lbs/day 0.048
Ibs/day 0.134
lbs/day 0.030
Ibs/day 0.032
lbs/day 0.129
1bs/day 0.118
Ibs/day 0.188
ug/L 0.423
lbs/day 0.053
lbs/day 0.041
Ibs/day 0.037
ug/L 0.025
lbs/day 0.033
Ibs/day 0.035
lbs/day 0.143
Ibs/day 0.066
Ibs/day 0.037
lbs/day 0.045
Ibs/day 0.068
lbs/day 0.119
lbs/day 0.037
Ibs/day 0.025

OCPSF
Daily
Maximum
Parameter
-. OCPSF
Monthly
Average
1tg/L
OCPSF.
Daily •
Maximum
lbs/day
,OCPSF
Average.,'
lbs/day:
Pyrene 67 25 0.111 0.041 FC
Tetrachloroethylene 56 22 0.093 0.037 SS
Toluene 80 26 0.133 0.043 SS
Total Chromium 2770 1110 4.597 1.842 SS
Total Copper 3380 1450 5.610 2.407 SS -AL
Total Cyanide 1200 420 1.992 0.697 SS
Total Lead 690 320 1.145 0.531 SS
Total Nickel 3980 1690 6.605 2.805 SS
Total Zinc 2610 1050 4.332 1.743 SS -AL
1,2,4-Trichlorobenzene 140 68 0.232 0.113 FC
1,1,1-Trichloroethane 54 21 0.090 0.035 FC
1,1,2-Trichloroethane 54 21 0.090 0.035 FC
Trichloroethylene 54 21 0.090 0.035 PC
Vinyl Chloride 268 104 0.445 0.173 SS
Standard
?Aqualic Life
µ8/1; •
OCPSF Subpart 1 Caictjations
Human
Health
Standard
Water
Consumption
Standard
none 4000 830 no
none 303 0.7 yes
11 none none no
50 none none no
7 none 1300 no
5 220000 700 no
25 none none no
88 4600 25 no
50 none none no
61 none 35 no
none 4.4 0.54 no
none 16 0.59 yes
none 30 2.5 yes
none 2.4 0.025 yes
Column Calcs:
1 OCPSF Guidelines (see 40 CFR 414.90)
2 OCPSF Guidelines (see 40 CFR 414.90)
3 col 1 * OCPSF Flow * 8.34/1000
4 col 2 * OCPSF Flow * 8.34/1000
5, 6. 7. 8, 9 from Fcd /state water quality standards
10 if WS class then find minimum oleo! 6, 7, & 8. Otherwise fed minimum of col 6 & 7. [i.e., which is the more stringent]
11 if parameter is a carcinogen then all load = 8.34 * Qavg* col 10 /1000. Otherwise all load = 8.34 . 7Q 10 * col 10 /1000.
12 copy of column 3
13 find minimum of col 11 and 12.
14 note which load is lower.
15 if limit is not based on OCPSF guidelines then calculate concentration based on Qp. Otherwise copy OCPSF load
16 if limit is not based on OCPSF guidelines then use units of'ug/1'. Otherwise use'Ids/day'.
17 if limit is not based on OCPSF guidelines then leave balnlc. Otherwise copy OCPSF limits from col. 4.
•
4/15/2009
Minimum
criteria
water Qual
• ':Allowable
Load
• lbs/daY'
OCPSF.
Daily
Maximum
lbs/day
•:: Find �,.
M'mimum
Dally
Maximum
limit
Units
Monthly
•Average
Limit
lbs/day
4,000 17,034 0.111 0.111 OCPSF 0.111 Ibs/day 0.041
303 7.076 0.093 0.093 OCPSF 0.093 Ibs/day 0.037
11 47 0.133 0.133 OCPSF 0.133 lbs/day 0.043
50 213 4597 4597 OCPSF 4597 lbs/day 1.842
7 30 5.610 5.610 OCPSF 5.610 Ibs/day 2.407
5 21 1.992 1.992 OCPSF 1.992 lbs/day 0.697
25 106 1.145 1.145 OCPSF 1.145 Ibs/day 0.531
88 375 6.605 6.605 OCPSF 6.605 Ibs/day 2.805
50 213 4.332 4.332 OCPSF 4.332 lbs/day 1.743
61 260 0.232 0.232 OCPSF 0.232 Ibs/day 0.113
4.4 19 0.090 0.090 OCPSF 0.090 Ibs/day 0.035
16 374 0.090 0.090 OCPSF 0.090 lbs/day 0.035
30 701 0.090 0.090 OCPSF 0.090 lbs/day 0.035
2.4 56 0.445 0.445 OCPSF 0.445 Ibs/day 0.173

Joe's Notes - Limits Calculations
Monthly Average Flows in MGD DAK Americas, LLC NC0003719
Jan-05 0.179
Feb-05 0.194
Mar-05 0.178
Apr-05 0.085
May-05 0.032
Jun-05 0.189
JuI-05 0.278
Aug-05 0.242
Sep-05 0.147
Oct-05 0.203
Nov-05 0.282
Dec-05 0.227
Jan-06 0.209
Feb-06 0.209
Mar-06 0.203
Apr-06 0.173
May-06 0.200
Jun-06 0.191
JuI-06 0.276
Aug-06 0.388
Sep-06 0.358
Oct-06 0.182
Nov-06 0.284
Dec-06 0.260
Jan-07 0.236
Feb-07 0.306
Mar-07 0.166
Apr-07 0.126
May-07 0.171
Jun-07 0.177
Jul-07 0.209
Aug-07 0.198
Sep-07 0.221
Oct-07 0.141
Nov-07 0.118
Dec-07 0.154
Jan-08 0.203
Feb-08 0.229
Mar-08 0.176
Apr-08 0.182
May-08 0.165
Jun-08 0.223
Jul-08 0.288
Aug-08 0.256
Sep-08 0.211
Oct-08 0.175
Nov-08 0.170
Dec-08 0.182
Flow History (MGD):
0.199 4-Year Ave (Jan2005-Dec2008)
0.388 Highest Monthly Average (Aug 2006)
0.032 Lowest Monthly Ave (May 2005)
0.603 Max daily flow (Sep 10, 2008) for Jan2005-Dec2008
... according to 40 CFR, Subpart D, 414.41 (BPT)
Limits Calc: Daily Max Monthly Ave
BOD5
TSS
64 x 0.603 = 38.59 mg/L
130 x 0.603 = 78.39 mg/L
Do not use.
24 x 0.388 = 9.31 mg/L
40 x 0.388 = 15.52 mg/L
Do not use.
Considering EPA prefers to use the 4-year average flow:
BOD5
Daily Max
Monthly Ave
TSS
Daily Max
Monthly Ave
COD
(64 x 0.199 MGD)
(24 x 0.199 MGD)
(130 x 0.199 MGD)
(40 x 0.199 MGD)
BPT
64
24
mg/L
12.72
9.31
130 25.84
40 7.95
Limit
21.11 Ibs/day
15.45 Ibs/day
215.76 lbs/day
66.39 Ibs/day

IWC Calculations
DAK Americas, LLC - Cedar Creek Site
NC0003719
Prepared By: Joe Corporon, NPDES Program
Enter Permitted Flow (MGD):
Enter s7Q10(cfs):
Enter w7Q10 (cfs):
0.300
791
Residual Chlorine
7Q10 (CFS)
PERMITTED FLOW (MGD)
PERMITTED FLOW (CFS)
STREAM STD (UG/L)
UPS BACKGROUND LEVEL (l
IWC (%)
Allowable Conc. (ug/I)
Fecal Limit
(If DF >331; Monitor)
(If DF <331; Limit)
Dilution Factor (DF)
NPDES Server/Current Versions/IWC
791
0.3
0.465
17.0
0
0.06
28,935
Not Required
1,702
Ammonia (NH3 as N)
(summer)
7Q10 (CFS)
PERMITTED FLOW (MGD)
PERMITTED FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Conc. (mg/I)
Ammonia (NH3 as N)
(winter)
7Q10 (CFS)
PERMITTED FLOW (MGD)
PERMITTED FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Conc. (mg/I)
791
0.30
0.465
1.0
0.22
0.06
1328
791
0.3
0.465
1.8
0.22
0.06
2,689
4/15/2009

16 1
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a
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FOXTROT AVEMIE
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