NC0003719_Permit (Issuance)_20110919

NPDES DOCUMENT SCANNIN`: COVER SE►HEET
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 19, 2011
This document is printed on reuse paper. - igizore any
content on the INWIF4BriBe side

ti
ArA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 19, 2011
Mr. Craig Leite, Site Manager
DAK Americas LLC-Cedar Creek Site
P.O. Box 1690
Fayetteville, North Carolina 28302
Subject: Issuance of NPDES
Permit NC0003719
DAK Americas LLC-
Cedar Creek Site
Cumberland County
Facility Class I
Dear Mr. Leite:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued 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 15, 2007 (or as subsequently amended).
The final permit contains no significant changes from the Draft Permit.
This final permit maintains the following changes contained in the Draft Permit:
• Outfall 001 was added to the permit. The Outfall 001 has a combination of non -contact cooling water and
stormwater.
• The permit limits have recalculated based on the latest OCPSF production information.
• The winter BOD limits were eliminated from the permit based on the requirements of §40 CFR 414.
• The plastic bottle recycling facility has received an allocation for BOD and TSS.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable
to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt
of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh,
North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet www.ncwaterquardy.arg
M Equal Opportunity \ Affirmative Action Employer
Noe Carolina
7?aturaiij

Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements
to obtain other permits which may be required by the Division of Water Quality or permits 'required by the
Division of Land Resources, the Coastal Area Management Act or any other Federal or Local govemmental permit
that may be required. If you have any questions concerning this permit, please contact Sergei Chernikov at
telephone number [phone].
eoe
Sincerely,
oleen H. Sullins
cc: Central Files
NPDES Files
Fayetteville Regional Office / Surface Water Protection Section
Aquatic Toxicology Unit (e-copy)
EPA Region IV (e-copy)
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 AffirmaUve Action Employer
NorthCarolina
Naturally

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 andother conditions set forth in Parts I, II, III and IV
hereof.
This permit shall become effective December 1, 2011
This permit and authorization to discharge shall expire at midnight on October 31, 2016.
Signed this day September 19, 2011
een H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0003719
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions described herein.
DAK Americas LLC
is hereby authorized to:
1. continue to operate an existing 0.500 MGD wastewater treatment plant (WWTP) consisting of
• flow equalization,
• spill basin
• pH adjustment
• oil skimming
• dual aeration basins
• dual spill and settling basins (500,000 gallons capacity each)
• 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. discharge from said treatment works and plastics recycling facility via Outfall 002 (located on the
attached map) and discharge non -contact cooling water and stormwater from Outfall 001 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 Basin Sub -Basin: 03-06-15
Latitude: 34° 58' 42" N Longitude: 78° 47' 00" W
State Grid/Quad: I -I 23 NE / Cedar Creek, NC
North
Facility
Location
not to scale
x
NPDES Permit NC0003719
Cumberland County

Permit NC0003719
•a
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge from Outfall 002. Such discharges shall be limited and monitored by the Permittee as
specified below:
Effluent
Characteristics `..
...
Limits•
Monitoring.
� . .: Re rem is
qut en•
Monthly._
Average
.
,Daily
Maximum
e
M asurement
Frequency•
Sample
Type • ,
Sample'
Location 1
Flow
0.500 MGD
Continuous
Recording
I or E
Total Suspended Solids (TSS)
180 lbs /day
394.5 lbs/day
1/Week
Composite 2
E
BOD5, 20°C
157.6 lbs /day
286 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 Division shall consider all effluent total residual chlorine values reported below
50 µg/L to be in compliance with jhe permit. However, the Permittee shall continue to record and submit all values
reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L.
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.

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
Limits '
Monitoring
Requiiremen•ts
• �, , !,
- = r .
•
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Measurementp
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'Frequency
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Sam e -
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Samjn pl`^^�e
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4 L ca o.r- :
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t.•..
Acenaphthene
0.105
0.039
1/Year
Grab
Effluent
Acenaphthylene
0.105
0.039
1/Year
Grab
Effluent
Acrylonitrile
0.430
0.171
1/Year
Grab
Effluent
Anthracene
0.105
0.039
1/Year
Grab
Effluent
Benzene
0.242
0.066
1/Year
Grab
Effluent
Benzo(a)anthracene
0.105
0.039
1/Year
Grab
Effluent
3,4-Benzofluoranthene
0.108
0.041
1/Year
Grab
Effluent
Benzo(k)fluoranthene
0.105
0.039
1/Year
Grab
Effluent
Benzo(a)pyrene
0.108
0.041
1/Year
Grab
Effluent
Bis(2-ethylhexyl) phthalate
0.496
0.183
1/Year
Grab
Effluent
Carbon Tetrachloride
0.068
0.032
1/Year
Grab
Effluent
Chlorobenzene
0.050
0.027
1/Year _
Grab
Effluent
Chloroethane
0.476
0.185
1/Year
Grab
Effluent
Chloroform •
0.082
0.037
1/Year
Grab
Effluent
2-Chlorophenol
0.174
0.055
1/Year
Grab
Effluent
Chrysene
0.105
0.039
1/Year
Grab
Effluent
Di-n-butyl phthalate
0.101
0.048.
1/Year
Grab
Effluent
1,2-Dichlorobenzene
0.290
0.137
1/Year
Grab
Effluent
1,3-Dichlorobenzene
0.078
0.055
1/Year
Grab
Effluent
1,4-Dichlorobenzene
0.050
0.027
1/Year
Grab
Effluent
1,1-Dichloroethane
0.105
0.039
1/Year
Grab
Effluent
1,2-Dichloroethane
0.375
0.121
1/Year
Grab
Effluent
1,1-Dichloroethylene
0.044
0.028
1/Year
Grab
Effluent
1,2-trans-Dichloroethylene
0.096
0.037
1/Year
Grab
Effluent
2,4-Dichlorophenol
0.199
0.069
1/Year
Grab
Effluent
1,2-Dichloropropane
0.409
0.272
1/Year
Grab
Effluent
1,3-Dichloropropylene
0.078
0.052
1/Year
Grab
Effluent
Diethyl phthalate
0.361
0.144
1/Year
Grab
Effluent
2,4-Dimethylphenol
0.064
0.032
1/Year
Grab
Effluent
Dimethyl phthalate
0.083
0.034
1/Year
Grab
Effluent
4,6-Dinitro-o-cresol
0.492
0.139
1/Year
Grab
Effluent
2,4-Dinitrophenol
0.218
0.126
1/Year
Grab
Effluent
Ethylbenzene
0.192
0.057
1/Year
Grab
Effluent
Fluoranthene
0.121
0.044
1/Year
Grab
Effluent
Fluorene
0.105
0.039
1/Year
Grab
Effluent
[Part A. (1.) continues on next page]

Permit NC0003719
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(OCPSF - Continued)
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t= _
Loc_tton
:'.�`4 - -y`4- ,. ,�1 ..
Hexachlorobenzene 1
1.6 µg/L
1.6 µg/L
1/Year
Grab
Effluent
Hexachlorobutadiene
0.087
0.036
1/Year
Grab
Effluent
Hexachloroethane
0.096
0.037
1/Year
Grab
Effluent
Methyl Chloride
0.338
0.153
1/Year
Grab
Effluent
Methylene Chloride
0.158
0.071
1/Year
Grab
Effluent
Naphthalene
0.105
0.039
1/Year
Grab
Effluent
Nitrobenzene
0.121
0.048
1/Year
Grab
Effluent
2-Nitrophenol
0.123
0.073
1/Year °
Grab
Effluent
4-Nitrophenol
0.220
0.128
1/Year
Grab
Effluent
2,6-Dinitrotoluenei
49.0 µg/L
49.0 µg/L
1/Year
Grab
Effluent
Phenanthrene
0.105
0.039
1/Year
Grab
Effluent
Phenol
0.046
0.027
.1/Year
Grab
Effluent
Pyrene
0.119
0.044
1/Year
Grab
Effluent
Tetrachloroethylene
0.099
0.039
1/Year
Grab
Effluent
Toluene
0.142
0.046
1/Year
Grab
Effluent
1,2,4-Trichlorobenzene
0.249
0.121
1/Year
Grab
Effluent
1,1,1-Trichloroethane
0.096
0.037
1/Year
Grab
Effluent
1,1,2-Trichloroethane
0.096
0.037
1/Year
Grab
Effluent
Trichloroethylene
0.096
0.037
1/Year
Grab
Effluent
Vinyl Chloride
0.476
0.185
1/Year
Grab
Effluent
Metals and Toxicants
Total Chromium
4.92
1.97
1/Year
Grab
Effluent
Total Copper
6.0
2.58
1/Year
Grab
Effluent
Cyanide
2.13
0.75
1/Year
Grab
Effluent
Total Lead
1.23
0.57
1/Year
Grab
Effluent
Total Nickel
7.07
3.0
1/Year
Grab
Effluent
Total Zinc
4.64
1.87
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 Section
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section 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 chemicallphysical 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.

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.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until permit expiration, the Permittee is
authorized to discharge from outfall(s) serial number 001 (Non -Contact Cooling Water and Stormwater). Such
discharges shall be limited and monitored by the permittee as specified below:
STORMW TER .
DISARC! CTURGE`
;CHAERISTIC
S j - A.
ly
.
_ =
•
LIMITSi
-
MONITORING
.
-->c iY^ yL. _
1
-REQUIREMENTS .
Ll.. .. >...w< i
Units
Limit
statement
J giidr�c'
dill It
T�
_ Sample w
Location
Total Flow3
MG
Annual
SW-1
Total Rainfall3
Inches
Annual
SW-1
Event Duration3
Minutes
Annual
SW-1
Total Suspended
Solids
mg/L
100.00
Annual
Grab
SW-1
Notes:
1. Measurement frequency. Once per year. The facility must perform analytical sampling during the
first full year and last year of the permit term regardless of cut-off concentration conditions.
Analytical results from sampling during the final year of the permit term must be submitted with
the permit renewal application. Failure to monitor storm events in accordance with the specified
frequency shall constitute a violation of this permit.
2. Sample Location. Samples to be collected at the stormwater discharge outfall (SW-1) located north
of the river water intake pump overflow and south of the sludge drying beds.
3. For each sampled representative storm event the total precipitation, storm duration, and total flow
must be monitored. Total flow shall be either: (a) measured continuously, (b) calculated based on
the amount of area draining to the outfall, the amount of build -upon (impervious) area, and the
total amount of rainfall, or (c) estimated by the measurement of flow at 20 minute intervals during
the rainfall event (not to exceed three hours).

Permit NC0003719
For purposes of the stormwater sampling required in this permit, all samples shall be collected from a
discharge resulting from a representative storm event.

1
Chernikov, Sergei
From: [e-mail]
Sent: Monday, August 15, 2011 3:44 PM
To: Chemikov, Sergei
Subject: DAK Americas, LLC NC0003719
Sergei,
I appreciate you sending this draft permit for our review.
We have no comments at this time. As always, if substantial changes to the draft permit are
made prior to issuance please allow Region 4 another opportunity to review the draft permit.
Sincerely,
Pamala Myers
Environmental Engineer and Technical Advisor Pollution Control and Implementation Branch
Water Protection Division Municipal and Industrial NPDES Section U.S. EPA, Region 4 Atlanta,
GA 30303
404.562.9421
404.562.8692 (fax)
1

AFFIDAVIT OF PUBLICATION
NORTH CAROLINA
Cumberland County
Public Notice
North Carolina Environmcn
tal Management
Commission/NPDES Unit
1617 Mail Senice 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 -
doe. The Director of the NC
Division of Water Quality
(DWQ) may hold a public
hearing should there be a
significant degree of public
interest Please mail 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 penults and this no-
tice may be found on our
wcbsitc:
http://portal.ricdenr.org/web/
w /swpp/ps/n des/calendar,
or by calling (919) 807-630.1.
DAK Americas LLC - Cedar
Creek Site (NC0003719) re-
quested renewal of its per -
ndt In Cumberland County;
this facility discharges treat -
ed wastewater to the Cape
Fear River in the Cape Fear
River Basin.
Notice of Intent to Issue a
NPDES Wastewater Permit
7/26 3322396
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
PROPOSSES TO ISSUE A NPDES WASTEWATER DI
of NC DIVISION OF WATER QUALITY
was inserted in the aforesaid newspaper in space, and on dates as follows:
7/26/2011
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 29 day
of July, A.D., 2011.
In Testimony Whereof, I have hereunto set my hand and affixed my
official seal, the day and year aforesaid.
Pamela H. Walters, Notary Public
My commission expires 5th day of December, 2015.
MAIL TO: NC DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-00001617
0003322396

FACT SHEET
Renewal of Permit NC0003719
SUMMARY
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 Description. DAK Americas, LLC 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. The facility also recycles plastic bottles and treat the
wastewater generated by this operation.
While maintaining its surface -water discharge, DAK connected to Fayetteville's sewer -collection system
on May 1, 2006 to the Fayetteville Public Works Commission (PWC). However, the facility continues to
use on -site wastewater treatments to reduce costs.
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
0.500 MGD
Type of Waste:
OCPSF Outfall 002 (95% industrial, 5% domestic), Non -contact
cooling water and stormwater Outfall 001
Facility/Permit Status:
Grade III / Active; Renewal
County:
Cumberland County
Miscellaneous
Receiving Stream:
Cape Fear River
Regional Office:
Fayetteville
H23NE /
Cedar Creek, NC
Stream Classification:
C
State Grid /
USGS Quad:
303(d) Listed?
No
Permit Writer:
Sergei Chernikov
Subbasin:
03-06-15
Date:
June 17, 2011
Drainage Area (mi2):
4395
1411111111161411j.
Lat. 34° 58' 42" N Long. 78° 47' 00" \V
Summer 7Q10 (cfs)
791
Winter 7Q10 (cfs):
30Q2 (cfs)
Average Flow (cfs):
4340
1WC (%):
0.1%
FINAL Fact Sheet
Renewal -- NPDES Permit NC0002305
Page 1

PERMITTING APPROACH
Whole Effluent Toxicity (WET) Testing. Considering that DAK's discharge constitutes less than one
percent of the receiving stream (IWC 0.1% at 0.500 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 during the past permit cycle.
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.
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). During the period from January 2007 through May
2011 this facility received two NOVs: 03/27/2009 - for ammonia limit violation, and 07/17/2009 for BOD
limit violation. Compliance Evaluation Inspection conducted on 07/21/2010 determined that the facility is
in compliance.
Stormwater/Cooling Water Outfall — DAK has requested that this renewal combine under a single permit,
their effluent discharge with their existing combined stormwater and non -contact cooling water outfall. This
change will be made.
Federal Regulations Applicable to Renewal —In accordance 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 of 0.213
MGD to calculate both Daily Maximum and Monthly Average permit limits for BOD5 and TSS
Parameter Limit Calculations
§40 CFR 414.40, Subpart D
(Flow in MGD)
Renewal Limits
(lbs./day)
Parameter
For Daily
Maximum
For Monthly
Average
Daily
Maximum
Monthly Average
BOD,5-day
8.34 x 64 x 0.213 1
8.34x24x0.2131
114
43
TSS
8.34 x 130 x 0.213 1
8.34 x 40 x 0.213 1
231
71
pH
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
1 The Division used the average OCPSF flow of 0.213 MGD for both Daily Maximum and Monthly Average
limits, as recommended by EPA.
Fact Sheet for Permit Renewal - 2009
NPDES NC0003719
Page 2

Plastic Bottle Recycling Facility — The wastewater discharged from this facility contains BOD and TSS.
Therefore, allocations for these parameters will be added in the renewed permit.
BOD (monthly average) = 825 mg/L (avg. conc.) x 0.111 MGD (average flow) x 0.15 (assuming 85%
removal) x 8.34 (conversion factor)=114.6lb/day
i BOD (daily maximum)=114.6lb/day x 1.5 (conversion factor for secondary treatment) = 1721b/day
TSS (monthly average) = 785 mg/L (avg. conc.) x 0.111 MGD (average flow) x 0.15 (assuming 85%
removal) x 8.34 (conversion factor) =109lb/day
TSS (daily maximum) = 1091b/day x 1.5 (conversion factor for secondary treatment) = 163.51b/day
Permit BOD and TSS Limits — These limits were calculated by adding the allocation for plastic bottle
recycling facility and allocations for the OCPSF production lines.
BOD (monthly average)=114.6lb/day + 431b/day = 157.6 lb/day
BOD (daily maximum) =172lb/day + 1141b/day = 286 lb/day
TSS (monthly average) = 109 lb/day + 71 lb/day = 180 lb/day
TSS (daily maximum)=163.5lb/day + 231 lb/day = 394.5 lb/day
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 µg/L) times the process wastewater flow.
Again, the Division used the average flow of 0.213 MGD.
Each parameter's resultant limit was further evaluated against existing state and federal standards to find the
more stringent (see attached Excel 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 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.
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. None of these parameters show reasonable potential to exceed
water -quality standards. [These metals require limits under 40 CFR despite RPA findings]
Ammonia Nitrogen (NH3) History — Consistent with the original Monsanto permit, the previous permit,
and receiving stream modeling, DWQ calculated a summer Monthly Average ammonia nitrogen (NH3)
limits for renewal based on an equivalent mass -to -flow ratio. Previous limit:
• 0.859 MGD - corresponding to summer Monthly Average limit of 23 lbs/day
• 1.25 MGD - corresponding to summer Monthly Average limit of 35 lbs/day
Fact Sheet for Permit Renewal - 2009
NPDES NC0003719
Page 3

f
For Renewal at 0.500 MGD, this ratio equates to:
• 13 lbs/day
• 26 lb./day
• 26 lbs/day
• 52 lbs/day
Monthly Average (summer)
Daily Maximum (summer - doubled the Monthly Average)
Monthly Average (winter - doubled the summer Monthly Average)
Daily Maximum (winter - doubled the Monthly Average)
Winter limits are doubled months since dissolved oxygen is less of a concern during the colder
season. The Division judges these limits consistent since 1995 and appropriate for renewal.
PROPOSED CHANGES:
• Outfall 001 was added to the permit. The Outfall 001 has a combination of non -contact cooling
water and stormwater.
• The permit limits have recalculated based on the latest OCPSF production information.
• The winter BOD limits were eliminated from the permit based on the requirements of §40 CFR
414.
• The plastic bottle recycling facility has received an allocation for BOD and TSS.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: July 19, 2011.
Permit Scheduled to Issue: September 12, 2011.
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact
Sergei Chernikov at [phone] ([e-mail]).
Fact Sheet for Permit Renewal - 2009
NPDES NC0003719
Page 4

OCPSF Subpart I Calculations
FACILITY =>
NI'DES Permit ti =>
OCPSF Flow -i
QP =>
WS Class ?
7Qt0s=>
Average Strean Flow =>
DAK Americas, LLC -- Fayettevil
NC0003719
0.21 win
o.,II \1ilD
no
791 cfs
4,340 cfs
le, NC
[OCI'SI' flow
Limit Calculations per 40 CFR, Subpart I -- 414.90 and 91
(Comparisons to state standards and criteria)
* Standards and Criteria Updated 27Mar2009
Standards and Criteria
3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Parameter
Acenaphthene
Acenaphthylene
Acryloniuilc
Anthraccne
Benzene
Benzo(a)anthracene
3,4-Benzo Iluoranthene
Benzo(k)Buoranthene
Benzo(a)pyrene
Bis(2-ethylhexyl) phthalate
Carbon Tetrachloride
Chlorobenzene
Chlorocthane
Chloroform
2-Chlorophenol
Chrysenc
Di-n-butyl phthalate
1,2-Dichlorobenzcne
I,3-Dichlorobenzene
1,4-Dieldutubcnzene
1,I-Dichlorocthane
1 2-Dichlorocthane
I , I-Dichlorocthylene
1,2-trans-Dichloroethylene
2,4-Dicldorophenol
1,2-Dichloropropane
1,3-Dichloropropylene
Diethyl phthalate
2,4-Dimethylphenol
Dinrethyl phthalate
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluenc
2,6-Dinitrotoluenc
Ethylbertzene
Fluoranthene
Fluorene
Hexachlorobenzene
H ex ac Ir l orobuta dien e
Hexachloroethane
Methyl Chloride
Methylene Chloride
Naphthalene
Nitrobenzene
2-Nitrophcnol
4-Nitrophcnol
Phenanthrene
Phenol
Pyrenc
OCPSF
Daily
Maximum
Itg/L
OCPSF
Monthly
Average
µg/L
OCPSF
Daily
Maximum
lbs/day
OCPSF
Monthly
Average
Ibs/day
Federal
Criteria or
State
Standard
Standard
Aquatic
Life
Itg/L
Hunan
Health
Standard
Itg/L
Water
Consumption
Standard
pl;/L
Carcinogen?
Minimum
criteria
pg/L
Water Qual
Allowable
Load
lbs/day
OCPSF
Daily
Maximum
Ibs/day
Find
Minimum
Limit
Based On:
Daily
Maximum
Lintit
Units
Monthly
Average
Limit
Ibs/day
59 22 0.105 0.039 FC 60 None 20 no 60 255.62 0.105 0.105 OCPSF 0.105 Ibs/day 0.039
59 22 0.105 0.039 FC none none none no none none 0.105 0.105 OCPSF 0.105 Ibs/day 0.039
242 96 0.430 0.171 FC none 0.25 0.051 yes 0.25 5.84 0.430 0.430 OCPSF 0.430 Ibs/day 0.171
59 22 0.105 0.039 FC 0.05 40000 9600 no 0.05 0.21 0.105 0.105 OCPSF 0.105 Ibs/day 0.039
136 37 0.242 0.066 SS none 51 1.19 yes 51.00 1191 0.242 0.242 OCPSF 0.242 Ibs/day 0.066
59 22 0.105 0.039 FC none 0A311 0.0028 yes 0.03 0.73 0.105 0.105 OCPSF 0.105 Ibs/day 0.039
61 23 0.108 0.041 FC none 0.0311 0.0028 yes 0.03 0.73 0.108 0.108 OCPSF 0.108 lbs/day 0.041
59 22 0.105 0.039 FC none 0.0311 0.0028 yes 0.03 0.73 0.105 0.105 OCPSF 0.105 lbs/day 0.039
61 23 0.108 0.041 FC none 0.0311 0.0028 yes 0.03 0.73 0.108 0.108 OCPSF 0.108 lbs/day 0.041
279 103 0.496 0.183 FC none 2.2 1.2 yes 2.20 51.38 0.496 0.496 OCPSF 0.496 lbs/day 0.183
38 18 0.068 0.032 SS none 1.6 0.254 yes 1.6 37.37 0.068 0.068 OCPSF 0.068 Ibs/day 0.032
28 15 0.050 0.027 FC 130 none 140 no 130 554 0.050 0.050 OCPSF 0.050 Ibs/day 0.027
268 104 0.476 0.185 FC none none none no none none 0.476 0.476 OCPSF 0.47fi lbs/day 0.185
46 21 0.082 0.037 SS none 170 5.6 yes 170 3971 0.082 0.082 OCPSF 0.082 lbs/day 0.037
98 31 0.174 0.055 FC none 400 0.1 no 400 1704 0.174 0.174 OCPSF 0.174 Ibs/day 0.055
59 22 0.105 0.039 FC none 0.018 none yes 0.018 0.42 0.105 0.105 OCPSF 0.105 Ibs/day 0.039
57 27 0.101 0.048 FC 9.5 none none no 10 40.47 0.101 0.101 OCPSF 0.101 Ibs/day 0.048
163 77 0.290 0.137 FC 470 17000 2700 no 470 2002 0.290 0.290 OCPSF 0.290 Ibs/day 0.137
44 31 0.078 0.055 FC 390 2600 400 no 390 1662 0.078 0.078 OCPSF 0.073 lbs/day 0.055
28 15 0.050 0.027 FC 100 2600 400 no 100 426 0.050 0.050 OCPSF 0.050 lbs/day 0.027
59 22 0.105 0.039 FC 20000 17(1000 6700 no 20,000 85,205 0.105 0.105 OCPSF 0.105 lbs/day 0.039
211 68 0.375 0.121 FC none 37 0.38 yes 37 864 0.375 0.375 OCPSF 0.375 Ibs/day 0.121
25 16 0.044 0.028 FC none 7100 330 yes 7,100 165,829 0.044 0.044 OCPSF 0.044 lbs/day 0.028
54 21 0.096 0.037 FC none 10000 140 no 10,000 42,603 0.096 0.096 OCPSF 0.096 lbs/day 0.037
112 39 0.199 0.069 FC none none none no none none 0.199 0.199 OCPSF 0.199 lbs/day 0.069
230 153 0.409 0.272 FC none 15 0.5 no 15 64 0.409 0.409 OCPSF 0.409 lbs/day 0.272
44 29 0.078 0.052 FC none 21 0.31 no 2I 89 0.078 0.078 OCPSF 0.078 Ibs/day 0.052
203 81 0.361 0.144 FC 1200 none none no 1,200 5,112 0.361 0.361 OCPSF 0.361 Ibs/day 0.144
36 18 0.064 0.032 SS 320 note none no 320 1,363 0.064 0.064 OCPSF 0.064 lbs/day 0.032
47 19 0.083 0.034 PC 3400 none none no 3,400 14,485 0.083 0.083 OCPSF 0.083 lbs/day 0.034
277 78 0.492 0.139 FC none 765 13.4 no 765 3,259 0.492 0.492 OCPSF 0.492 lbs/day 0.139
123 71 0.218 0.126 FC 26 none none no 26 111 0.218 0.218 OCPSF 0.218 Ibs/day 0.126
285 113 0.506 0.201 FC none 3.4 0.11 yes 3.4 79 0.506 0.506 OCPSF 0.506 lbs/day 0.201
641 255 1.139 0.453 FC none 0.048 0.71 no 0.048 0.20 1.139 0.204 WQ Standard 49.0 ug/L 0.453
108 32 0.192 0.057 FC 97 none none no 97 413 0.192 0.192 OCPSF 0.192 lbs/day 0.057
68 25 0.121 0.044 FC 0.11 none none no 0.11 0.47 0.121 0.121 OCPSF 0.121 lbs/day 0.044
59 22 0.105 0.039 FC 46 none none no 46 196 0.105 0.105 OCPSF 0.105 lbs/day 0.039
28 15 0.050 0.027 FC none 0.00023 0.00029 yes 0.0003 0.007 0.050 0.007 WQ Standard 1.6 ug/L 0.027
49 20 0.087 0.036 SS none 18 0.44 yes 18.0 420 0.087 0.087 OCPSF 0.087 lbs/day 0.036
54 21 0.096 0.037 FC none 3.3 1.4 yes 3.3 77 0.096 0.096 OCPSF 0.096 lbs/day 0.037
190 86 0.338 0.153 FC none 96 2.6 no 96 409 0.338 0.338 OCPSF 0.338 lbs/day 0.153
89 40 0.158 0.071 FC none 590 4.6 yes 590 13,780 0.158 0.158 OCPSF 0.158 lbs/day 0.071
59 22 0.105 0.039 FC 330 none none no 330 1,406 0.105 0.105 OCPSF 0.105 lbs/day 0.039
68 27 0.121 0.048 FC none 30 17 no 30 128 0.121 0.121 OCPSF 0.121 Ibs/day 0.048
69 41 0.123 0.073 FC 8000 none none no 8,000 34,082 0.123 0.123 OCPSF 0.123 Ibs/day 0.073
124 72 0.220 0.128 FC 750 none 270 no 750 3,195 0.220 0.220 OCPSF 0.220 Ibs/day 0.128
59 22 0.105 0.039 FC none none none ito none none 0.105 0.105 OCPSF 0.105 Ibs/day 0.039
26 15 0.046 0.027 FC none 300 300 no 300 1,278 0.046 0.046 OCPSF 0.046 Ibs/day 0.027
67 25 0.119 0.044 FC none 4000 330 no 4,000 17,041 0.119 0.119 OCPSF 0.119 Ibs/day 0.044
8/9/2011

Parameter
OCPSF
Daily
Maximum
µg/L
OCPSF
Monthly
Average
µg/L
OCPSF
Daily
Maximum
lbs/day
OCPSF
Monthly
Average
Ibs/day
Federal
Criteria or
State
Standard
Standard
Aquatic
Life
µg/L
OCPSF
Sttaa
rt 1 Calculalion
Human Water
Health Consumption
Standard Standard
pg/L 1110-
Carcinogen?
Minimum
criteria
µg/l.
Water Qual
Allowable
Load
Ibs/day
OCPSF
Daily
Maximum
Ibs/day
Find
Minimum
Limit
Rased Om
Daily
Maximum
Limit
Units
Monthly
Average
Limit
Ibs/dav
Tetrachloroettrylene 56 22 0.099 0.039 SS none 303 0.7 yes 303 7.077 0.099 0.099 OCPSF 0099 Ibs/day 0.039
Toluene 80 26 0.142 0.046 SS 11 none none no II 47 0.142 0.142 OCPSF 0.142 Ibs/day 0.046
Total Chromium 2770 1110 4.921 1.972 SS 50 none none no 50 213 4.921 4.921 OCPSF 4.921 Ibs/day 1.972
Total Copper 3380 1450 6.004 2.576 SS -AL 7 none 1300 no 7 30 6.004 6.004 OCPSF 6.004 lbs/day 2.576
Total Cyanide 1200 420 2.132 0.746 SS 5 220000 700 no 5 21 2.132 2.132 OCPSF 2.132 lbs/day 0.746
Total Lead 690 320 1.226 0.568 SS 25 none none no 25 107 1.226 1.226 OCPSF 1.226 lbs/day 0.568
Total Nickel 3980 1690 7.070 3.002 SS 88 4600 25 no 88 375 7.070 7.070 OCPSF 7.070 Ibs/day 3.002
Total Zinc 2610 1050 4.636 1.865 SS -AL 50 none none no 50 213 4.636 4.636 OCPSF 4.636 Ibs/day 1.865
1,2,4-Trichlorobemene 140 68 0.249 0.121 FC 61 _-_none 35 no 61 260 0.249 0.249 OCPSF 0.249 Ibs/day 0.121
1,1.1-Tricbloroethane 54 21 0.096 0.037 FC none 4.4 0.54 no 4.4 19 0.096 0.096 OCPSF 0.096 lbs/day 0.037
1,1,2-Trichloroethane 54 21 0.096 0.037 FC none 16 0.59 yes 16 374 0.096 0.096 OCPSF 0.096 lbs/day 0.037
Trichloroethylene 54 21 0.096 0.037 FC none _ 30 2.5 yes 30 701 0.096 0.096 OCPSF 0.096 Ibs/day 0.037
Vinyl Chloride 268 104 0.476 0.185 SS none 2.4 0.025 yes 2.4 56 0.476 0.476 OCPSF 0.476 Ibs/day 0.185
Column Calcs:
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 • 834/1000
5, 6, 7, 8,9 from Fed / NC State water -quality standards
10 if WS class then find minimum of col 6, 7, & 8. Otherwise find 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 * 7Q10 * col 10 /1000.
12 copy ofcolumn3
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 balnk. Otherwise copy OCPSF limits from col. 4.
8/9/2011

DAK Americas LLC-cedar creek REASONABLE POTENTIAL ANALYSIS
NC0003719
Qw (MGD) =
1Q10S (cfs) =
7Q 1 OS (cfs) =
7QIOW (cfs) =
30Q2 (cfs) =
Avg. Stream Flow, QA (cfs) =
Receiving Stream:
0.50
636.40
791.00
NO 7Q10w DATA
NO 30Q2 DATA
1340.00
Cape Fear River
WWTP/WTP Class: III
IWC ® 1Q10S = 0.12%
IWC (4) 7Q1OS = 0.10%
IWC @ 7QIOW = N/A
IWC @ 30Q2 = N/A
IWC ® QA = 0.06%
Stream Class: Cape Fear River
Outfall 002
Qw=0.5 MGD
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)
-a
a
co
1-
m
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS /
Chronic
Applied
Standard
-
'h FAV /
Acute
n
# Det. Max Pred
Allowable Cw
Cw
Chromium
NC
50
FW(7Q10s)
1022
ug/L
12
0
8.2
Acute: 851,666.7
_ ____—_— _ _ __—_
Chronic: 50,000.0
No value > Allowable Cw
no limit
___----_ ___ —_ ____
-- - - -
Copper(AL)
NC
7
FW(7Q10s)
7
ug/L
12
3
56
Acute: 6,083.3
_ ____—_—__ _ _--_—
Chronic: 7,000.0
No value > Allowable Cw
no limit
_—______—_—_—_—.
- - — — —_—
Cyanide
NC
5
FW(7Q10s)
22
10
ug/L
12
1
5.0
Acute: 18,333.3
_ __ —_— _ ______---_—_—_—_—_—_—_—_—_—_—.
Chronic: 5,000.0
No value > Allowable Cw
no lima
Lead
NC
25
FW(7Q10s)
33.8
ug/L
12
4
8.4
Acute: 28,166.7
Chronic: --- 25,000.0
No value > Allowable Cw
Ino limit
---------------------------
Nickel
NC
25
WS(7Q10s)
261
ug/L
12
4
98.8
Acute: 217,500.0
_ ____—__ _ _ _--_—_—_—_—_—_—_—_—_—_—_—_—___
Chronic: 25,000.0
No value > Allowable Cw
no limit
Zinc (AL)
NC
50
FW(7Q10s)
67
ug/L
12
11
534.5
Acute: 55,833.3
_ chronic:--- 50,000A -
No value > Allowable Cw
no limit
--------------------------
Page 1 of 1
3719-RPA-2011.xlsm, rpa
8/9/2011

REASONABLE POTENTIAL ANALYSIS
Chromium
Date Data BDL=1/2DL Results
1 < 5 2.5 Std Dev.
2 5 2.5 Mean
3 5 2.5 C.V.
4 5 2.5 n
5 5 2.5
6 5 2.5 Mult Factor =
7 5 2.5 Max. Value
8 5 2.5 Max. Pred Cw
9 5 2.5
10 5 2.5
11 5 2.5
12 10 5
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -
Values" WITH
"COPY"
0.7217
2.7083
0.2665
12
Copper (AL)
1.63
5.0 ug/L
8.2 ug/L
Date Data BDL=1/2DL Results
1 8 8 Std Dev.
2 0.2 0.2 Mean
3 2 1 C.V.
4 2 1 n
5 3 3
6 3 1.5 Mult Factor =
7 3 1.5 Max. Value
8 3 1.5 Max. Pred Cw
9 3 1.5
10 3 1.5
11 2 1
12 20 10
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -
Values" WITH
"COPY"
3.0682
2.6417
1.1614
12
5.55
10.0 ug/L
55.5 ug/L
3719-RPA-2011.xlsm, data
- 4 - 8/9/2011

REASONABLE POTENTIAL ANALYSIS
Cyanide
Date Data BDL=1/2DL Results
1 < 5 5 Std Dev.
2 < 5 5 Mean
3 < 5 5 C.V.
4 8 5 n
5 < 5 5
6 < 5 5 Mult Factor =
7 < 5 5 Max. Value
8 < 5 5 Max. Pred Cw
9 < 5 5
10 < 5 5
11 < 5 5
12 < 5 5
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -
Values" WITH
"COPY"
0.0000
5.00
0.0000
12
Lead
1.00
5.0 ug/L
5.0 uglL
Date Data BDL=1/2DL Results
1 0.7 0.7 Std Dev.
2 0.1 0.1 Mean
3 0.2 0.2 C.V.
4 < 0.1 0.05 n
5 0.3 0.3
6 < 3 1.5 Mult Factor =
7 < 3 1.5 Max. Value
8 < 3 1.5 Max. Pred Cw
9 < 3 1.5
10 < 3 1.5
11 < 3 1.5
12 < 5 2.5
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -
Values" WITH
"COPY"
0.7759
1.0708
0.7246
12
3.34
2.5 ug/L
8.4 ug/L
3719-RPA-2011.xlsm, data
- 7 - 8/9/2011

REASONABLE POTENTIAL ANALYSIS
Nickel
Date Data BDL=1/2DL Results
1 < 5 2.5 Std Dev. 6.3741
2 < 5 2.5 Mean 6.0833
3 9 9 C.V. 1.0478
4 < 5 2.5 n 12
5 6 6
6 < 5 2.5 Mult Factor = 4.94
7 < 5 2.5 Max. Value 20.0 uglL
8 18 18 Max. Pred Cw 98.8 ug/L
9 < 5 2.5
10 < 5 2.5
11 < 5 2.5
12 20 20
SPECIAL -
Values" WITH
"COPY"
Zinc (AL)
Date Data BDL=1/2DL Results
1 17 17 Std Dev. 28.3143
2 12 12 Mean 26.3333
3 105 105 C.V. 1.0752
4 10 10 n 12
5 6 6
6 56 56 Mult Factor = 5.09
7 14 14 Max. Value 105.0 uglL
8 32 32 Max. Pred Cw 534.5 uglL
9 26 26
10 8 8
11 15 15
12 < 30 15
SPECIAL -
Values" WITH
"COPY"
3719-RPA-2011.xlsm, data
- 10 - 8/9/2011

,
Chernikov, Sergei
From: Lowther, Brian
Sent: Friday, July 08, 2011 2:41 PM
To: Chernikov, Sergei
Subject: RE: permit for DAK Americas LLC-cedar creek site NC0003719
Thanks Sergei. 1 am fine with moving forward with the permit from our perspective. I have reviewed our sw permit for
them and this is consistent with what we told them during the renewal. Thanks for letting me review it.
Brian
Brian C. Lowther
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Email: [e-mail]
Website: http://portal.ncdenr.org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and may be disclosed to third parties.
From: Chernikov, Sergei
Sent: Friday, July 08, 2011 1:47 PM
To: Lowther, Brian
Subject: RE: permit for DAK Americas LLC-cedar creek site NC0003719
Please see attached. You can stormwater portion.
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Lowther, Brian
Sent: Friday, July 08, 2011 1:34 PM
To: Chernikov, Sergei
Subject: RE: permit for DAK Americas LLC-cedar creek site NC0003719
1

t
Thanks Sergei,
Does the boiler plate address any stormwater information or definitions? Could I see the current boiler plate?
Brian
Brian C. Lowther
Environmental Engineer
NCDENR ! DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Email: [e-mail]
Website: http://portal.ncdenr.org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and may be disclosed to third parties.
From: Chernikov, Sergei
Sent: Friday, July 08, 2011 10:32 AM
To: Lowther, Brian
Subject: RE: permit for DAK Americas LLC-cedar creek site NC0003719
Brian,
Yes, we include the boiler plate language when we sent the permit to the facility.
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Lowther, Brian
Sent: Thursday, July 07, 2011 10:06 AM
To: Chernikov, Sergei
Subject: RE: permit for DAK Americas LLC-cedar creek site NC0003719
Thanks Sergei for letting me look over this. The permit seems fine. However, I do have one question about the permit
though because I am not as familiar with how they are written. Is this the entire permit given to the permittee or will
there be a stock boiler plate included? Thanks
2

07/01/2011 15:56 9104860707
NC DENR
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DIVISION OF WATER QUALITY
June 9, 2011
MEMORANDUM
TO: Dina Sprinkle
Point Source Branch
FROM: Dale Lopez, Environmental Specialist
THROUGH: Belinda S. Henson, Regional Supervisor Surface Water Protectio - : ection, FRO
SUBJECT: Renewal of NPDES Permit
DAK Americas LLC
NPDES No. NC0003719
Cumberland County
Please find enclosed a staff report and recommendations from the Fayetteville Regional
Office concerning the renewal of subject new NPDES Permit.
If you have any questions or require any further information, please advise.
Attachments

SOC PRIORITY PROJECT: YES NO X
If Yes, SOC No.
To: Permits and Engineering Unit
Water Quality Section
Attention: Dina Sprinkle
Date: June 9.2011
NPDES STAFF REPORT AND RECOMMENDATION
COUNTY: Cumberland
Permit No. NC0003719
PART I - GENERAL INFORMATION
1. Facility and Address: DAK Americas LLC
3468 Cedar Creek Road
Fayetteville, NC 28312
2. Date of Investigation: June 1, 2011
3. Report Prepared by: Dale Lopez, Environmental Specialist
4. Persons Contacted and Telephone Number: Donald Allbright, ORC
[phone]
5. Directions to Site: From Fayetteville travel NC 53 East. The plant is located 8 miles from
Fayetteville, NC
6. Discharge Point(s), List for all discharge points:
001 Latitude: 34° 58'42" N Longitude: 78° 47'• 00" W
002 Latitude: 34° 58'42" N Longitude: 78° 47' 00" W
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map.
U.S.G.S.Quad No. H23 NE
U.S.G.S. Quad Name: Cedar Creek. NC
7. Site size and expansion area consistent with application?
X Yes No (If no, explain)
8. Topography (relationship to flood plain): The wastewater treatment plant is on bluffbetween the plant
(manufacturing part) and the Cape Fear River. The site is not within the 100-year
flood plain.
9. Location of nearest dwelling: None within 1,000 feet

10. Receiving stream or affected surface waters:
a. Classification: Lower Little River Class C
b. River Basin and Subbasin No.: Cape Fear River Basin 03-06-15
c. Describe receiving stream features and pertinent downstream uses:
At this location the Cape Fear River is approximately 250 feet wide, approximately 20-feet deep,
well mixed. It is classified as Class C waters in this location, which promotes aquatic life
propagation and survival, fishing, wildlife, secondary recreation, and agriculture.
PART II - DESCRIPTION OF WASTES AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted: 1.25 MGD (Ultimate Design Capacity)
b. What is the current permitted capacity of the Wastewater Treatment facility? 0.5 MGD
c. Actual treatment capacity of the current facility (current design capacity). 1.25 MGD
d. Date(s) and construction activities allowed by previous Authorizations to Construct issued
in the previous two (2) years. None
e. Please provide a description of existing or substantially constructed wastewater treatment
facilities.
Please see Attachment A, as it contains the following: a) narrative description, b) colored
aerial view of the WWTP, c) Black/white aerial view of the WWTP with the identification of
each unit, and d) flow diagram of the WWTP and the Recycle Bottle Plant process units.
f. Please provide a description of proposed wastewater treatment facilities: N/A
f. Possible toxic impacts to surface waters:
DAK has several potential toxic substances related to the following. It is 40 CFR 414 (Organic
chemicals, plastics, and synthetic fibers --- OCPSF), Subcategory D. DAK and DuPont Teijin
Films are SIC Code 2821, and Clear Path Recycling is SIC Code 5162. This facility includes
DAK's polyester resins manufacturing operation, DuPont Teijin Films manufacturing operation,
Clear Path Recycling (with approximately 80 employees), and a Service Complex (that provides
utilities to the entire site). Please see Attachment B, as it contains the following: a) a description
of the manufacturing processes for DuPont Teijin Films, DAK Resin Plant, and Clear Path
Recycling, b) a colored aerial view of the entire plant site, and c) a flow diagram and water
balance sheet for the plant site. In reviewing the Whole Effluent Toxicity (WET) summary
records since January 2002, DAK was found to have had one failure (May 2003); the cause for the
WET failure (Pimephales promelas) was not determined.
h. Pretreatment Program (POTWs only):
In development
Should be required
Approved
Not needed X

2. Residuals handling and utilizing/disposal scheme:
a. If residuals are being land applied, please specify DWQ Permit No.
b. Residuals stabilization: PSRP
c. Landfill:
PFRP
Other
IDry solids from Clear Path Recycling are sent to Sampson County Landfill
d. Other disposal/utilization scheme (specify):
Residual Contractor:
McGill Environmental hauls the DAK sludge (not Clear Path Recycling sludge) for
composting
Telephone:
[phone]
3. Treatment plant classification (attach completed rating sheet):
See WWTP classification attachmenlj
4. SIC Code (s):
Main Treatment Unit Code:
PART III — OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds (municipals only)?
N/A
2. Special monitoring or limitations (including toxicity) requests: N/A
3. Important SOC, JOC or Compliance Schedule dates (please indicate): NA
Date
Submission of Plans and Specifications N/A
Begin Construction .N/A
Complete Construction N/A
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options
available? Please provide regional perspective for each option evaluated.
Spray Irrigation: N/A

Connection to Regional Sewer System:
On May 31, 2006, the PERCS Unit sent an Industrial Pretreatment approval letter for DAK (IUP#
2116RF) to discharge wastewater to the Fayetteville PWC Rockfish WWTP. During the time
period that followed, DAK sent approximately one-third of their total flow to PWC. During 2010,
DAK chose to discontinue sending any wastewater to PWC. On December 20, 2010, the PERCS
Unit sent a Drop Approval Letter to PWC that acknowledged that the DAK IUP was officially
dropped from the PWC pretreatment program because the SIU had ceased to discharge process
wastewater to the POTW and thus no longer met the definition of a Significant Industrial User.
DAK has also chosen not discharge its domestic sewage to the POTW.
Subsurface: N/A
Other disposal options: N/A
5. Other Special Items:
DAK is presently a member of the Cape Fear River Assembly. Instream Cape Fear River
monitoring is performed by this group.
PART IV - EVALUATION AND RECOMMENDATIONS
Please consider the following items that the Fayetteville Regional Office would like to be reviewed and
modified, if appropriate.
a. The latitude and longitude for the location that Outfall 001 and Outfall 002 mixed together before
flowing into the Cape Fear River were Latitude 34° 58' 42" and Longitude 78° 47' 00", as
according to Google Earth and Terrain Navigator. Please consider changing to these coordinates
in the permit.
b. The domestic wastewater from eighty employees at Clear Path Recycling flow directly into the
aeration basin (AB-1). The recent Fecal Coliform analyses (please see Attachment F) indicated a
large increase on September 29, 2010, and several very high results since then (up to 21,400
colonies/100 mL on February 16, 2011. Clear Path Recycling came on-line on July 14, 2010.
Please consider the addition to the Outfall 002 requirements for Fecal Coliforms limits and a
disinfection method (if chlorine, then please consider requiring a 28 µg/L chlorine limit). Please
note that this facility already has a chlorine contact chamber that is on-line; at the present, it is
without chlorination and dechlorination.
c. For the non -contact cooling tower water and blowdown that commingles with the stormwater
ditch, please consider either of the following: 1) the addition of Outfall 001 to this NPDES permit
(please see DAK's request in Attachment D), or 2) a general wastewater permit (NCG500000) for
the non -contact cooling water and cooling tower blowdown. Please see DAK's request in
Attachment D. Please also see email correspondence in Attachment C.
d. Please consider dropping the Nickel, Lead, and Di-N-Butyl Phthalate from the permit for the non -
contact cooling water and blowdown that commingles with the stormwater ditch, and that flows to
the sample location that has been designated by each of the following: SW-1, MH-1, and Outfall
001. (Please see Attachments D and the Attachment E list).
e. Please consider adding into the description of the wastewater treatment plant that there are now
"dual spill and settlin basins" (500,000 gallons ca acity each). Please keep in the description
at there is still another basin, the "main spill basin".

The wastewater treatment adequately treats the wastewater generated from DAK Resins Plant,
Clear Path Recycling, and the Dupont Teij in Film Plant. Based on the June 1, 2011 site inspection,
records review, and permit application information, it is recommended that the DAK NPDES Permit be
issued for an additional 5-year term. The two outfalls to be included in the permit are 002 (process water
lines from all sources) and 001 (which is DAK's storm water discharge that is combined with non -contact
cooling water blowdown wastewater from the DAK Service Complex).
1-1,LC/ 6/9/0?oil
Signature of Report Preparer
ti,,,,,O&D
Water Quality Regional Supervisor
Date

Q
Wastewater Treatment System Operation
Present Operating Status
The wastewater collection and treatment network consists of the following key sys-
tems: Outfall 001 for stonnwater and Outfall 002 for effluent from the biotreatment sys-
tem. The two are segregated until the flows reach the Outfall box at the river, they then
mix together and are discharged to the river via the same pipe. These systems are de-
scribed below.
The wastewater treatment system of DAK's Cedar Creek site is an activated sludge
treatment system that consists of equalization, pH adjustment and nutrient addition, aera-
tion, clarification, and sludge digestion and disposal. The waste treatment system treats
industrial and sanitary discharges from DAK Americas, Clear Path Recycling, and the
DuPont Teijin Film. This wastewater must be treated prior to its discharge to the Cape
Fear River.
The wastewater treatment method used is a biological process that is divided into
five steps:
1. Collection and equalization of raw wastewater
The wastewater from the DAK Resins Plant, the Clear Path Recycling Plant, and the
DuPont Teijin Film Plant travel through separate lines into either of two Equalization
(EQ) Tanks. These Equalization Tanks have a capacity of 660,500 gallons each or a
combined storage of 1,300,000 gallons. The combined flow is then metered into the
pH control pit. The Chem -Lift station collects chemical waste flows from the DAK
utilities sump but bypasses EQ tanks for the pH Control Pit. The only other wastewa-
ter treated is domestic sewers from the DAK Services Complex that directly enters
the biological aeration basin.
DAK is also noting that two concrete -lined basins, each with a capacity of 500,000
gallons and which we commonly refer to as the settling basins is being added to the
description of the WWTP. These basins were built when the plant was originally
constructed and have been used occasionally as emergency basins to store high COD
influent for several days until the wastewater can be fed to the activated sludge sys-
tem.
2. Adjustment of pH and addition of nutrients
The pH control pit is divided into two chambers for nutrient and rough pH adjustment
followed by oil and grease removal along with final pH adjustment. Caustic is added

Ail, /1
in the first chamber to adjust the pH. Uran and phosphoric acid are also added in the
first chamber as nutrients. Defoaming chemicals and magnesium chloride can also be
added at this point as needed. The capacity of the pH control pit is 120,000 gallons.
3. Aeration
Activated sludge is used by the biotreatment system to process wastes. The raw
wastewater is combined with air and microorganisms and the soluble wastes are oxi-
dized through biochemical reactions. This reduces the `oxygen demand' of the water
so it can be safely discharged. There are two aeration basins; however, during normal
operation, only one is in service. Aerators provide oxygen as needed. Aeration Basin
1 has a capacity of 3,500,000 gallons and Aeration Basin 2 has a capacity of
1,200,000. Aeration Basin No. 2 can be used as either an aeration basin or as a di-
gester. Occasionally activated carbon is added to the aeration basin as a seed for the
coagulation of solids prior to clarification.
4. Clarification
After several days of detention time, this activated sludge is then settled in a clarifica-
tion process to remove suspended solids from the treated water. Sometimes the solids
do not settle very well, therefore polymers, Klaraid PC1224 and IC1172, are added at
the distribution box where the flow is leaving the aeration basins and entering the
clarifier to aid in coagulation. This allows for improved settling of solids and less sol-
ids in the effluent stream. This clarified effluent is discharged into the Cape Fear
River. The concentrated solids are recycled back into the aeration basins in order to
maintain a `steady state' waste treatment operation. This is called return activated
sludge (RAS). However, because the microbes are feeding on the wastewater chemi-
cals, their biomass is growing. Therefore a waste activated sludge (WAS) stream is
diverted from the RAS for further treatment. The diameter of the clarifier is 90 feet
and it has a capacity of 700,000 gallons.
5. Aerobic sludge digestion and disposal
Excess biomass is oxidized, or digested, by aerating the waste activated sludge in ba-
sins without influent feed. This reduces the amount of solids that have to be dis-
posed. A digester is available to treat the wasted activated sludge. The capacity of
the digester is 550,000 gallons. After several weeks of detention time, the sludge is
pumped to a sludge storage basin. The sludge storage basin has a capacity of
1,000,000 gallons. After settling, the sludge is pumped to sludge drying beds for de -
watering. There are three sand -drying beds with a capacity of 100,000 gallons each.
All decanted water from the storage basin and beds is returned to the Aeration Basins.
The solids from the drying beds are sent to the Sampson County Landfill or to McGill
Environmental for Composting.

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•
sN,
Fig DAK Americas Cedar Creek Site Wastewater Treatment Syst
?JOS;2008
Recycle Bottle Plant
Influent from process
DAK Resins
I Influent from process I 1
I Non -contact cooling water I
Screening I
LA/VDT/4-1— tR- r c
< �CEAlrif C
I Equalization 1
Non -contact
cooling water
to stormwater
Outfall001
( Stormwater I
Outfall 001 J
To Cape Fear River I
Dupont Teijin Film
( Outfall002
Neutralization
2 41-
'Spill Basin'
(Effluent from wastewater
!treatment plant
I Screening I
I Equalization Tanks j
1
DAK Resins, LLC
3216 Cedar Creek Road
Fayottovitlo. NC
Cumberland County!
NPDES Permit No. NC0003719
s
I DAP
Sanitary
Sewer
I AB2
Digesters
I To sludge storage i

7,4&///7EAJT ,8
Description of Manufacturing Processes
DuPont°Teijin Films.
The DuPont Batch Plant was constructed in 1975 and uses dimethyl terephthalate
(DMT) and ethylene glycol (EG) as the basic raw materials. The Batch Plant produces
primarily film grade polyethylene terephthalate (PET) but small quantities of other spe-
cialty polymers are also produced in the batch reactors.
Ten reactor trains are used for the batch esterification and polymerization processes.
EG and EG prepared with process catalysts and additives are mixed with DMT in the es-
terinterchange reactor where the polymerization process is initiated. This reaction is
conducted in two stages, the first at atmospheric pressure and the second under vacuum:,
During the esterification step, methanol is generated and removed .from the process. The
methanol is collected and returned to the DMT manufacturer for recycle. Upon comple-
tion of the esterification step, the mixture is transferred by pressure into another vessel
for polymer addition where the polymer chain is lengthened. The PET polymer from this
process is extruded, quenched and cut into chips which are transferred to silos for storage
prior to shipment to customers.
Crude EG, which is recovered from the esterification and polymerization, processes
is purified by the batch process in two distillation columns. This recovered EG is then
reused to make additional PET.
DAK Resin Plant
Continuous Polymerization (CP) Plant
The CP Plant was constructed in 1995 and started up in January 1996. Raw materi-
als for the continuous process include terephthalic acid (TA), EG, and isophthalic acid
(IPA). EG is combined with TA and IPA to make a slurry, which is fed to the esterifier
where it is heated to make an oligomer. The oligomer is transferred to the polymeriza-
tion, and polymerization takes place in several steps involving additives and heat. In the
final stages of polymer finishing, the polymer is filtered, extruded, quenched, chipped,
dried and sent as polymer chips to the Solid State Process (SSP).
Solid State Process (SSP)
The SSP involves heating the PET chip to modify the polymer chain. Upon comple-
tion of the SSP, the chips are placed in silos prior to shipment to customers.

r reopd-,)
Supporting Activities
The above facilities also generate wastewater which does not come in contact with
process contaminants. These non -contact streams include demineralized water treatment
blowdown, boiler blowdown, and cooling tower blowdown. In addition, there are sani-
tary waste streams which are routed to the biological treatment system. Other contribu-
tions to wastewater include scrubber effluent, laboratory activities, wash down from
maintenance activities such as steam cleaning of equipment and minor leaks from equip-
ment being repaired. For general housekeeping purposes and to clean residual amounts
of minor leaks and spill, various areas of the plant are periodically washed by spraying
them down with water. This water is routed tluough a process area chemical sewer to the
biotreatment system.
Wellman
Operations at the Fayetteville Wellman plant ceased in 2003.
Clear Path Recycling LLC
In 2010 Clear Path Recycling LLC built a recycle bottle plant that is capable of pro-
ducing 90 MM lb/year of clean clear flake and 30 MM lb/year of clean colored flake.
Bottle Storage
Bottles will be received in bales and stored outdoors on receiving pads and inside
trailers.
Debailing section
Inside existing warehouses the recycling process begins with debailing.
The aim of this section is to break the bottle bales and to grant a regular flow in line feed-
ing.
• Inclined conveyor belt: The feed end is sunk into the floor so that the entire bales can
be slid onto it. Bales are set on the ground next to the feed section where the wires
are cut and tied to a stationary fixture. The bottles are then pushed with a forklift onto
the belt. The conveyor belt is sized to store bales. This design allows the operator
time to perform other functions as well as loading the conveyor.

dr74(et)
FIot pre -washing Section
The patented pre -washing section removes the large and abrasive contaminates in a con-
tinuous form. This is accomplished using slow moving machines with very few moving
parts. This section recycles water from the flake washing section that would otherwise be
discharged -as waste:
• The hot pre- washing removes almost all paper labels
• This section uses a stainless steel jacketed and insulated cylinder, where the loose bot-
tles are mixed with a hot caL tic solution of water from the washing system to release
the label from the bottle J .O H
• This section also removes all major dirt, sand and glass from the outside of the bot-
tles.
Inspection table and metal sorting .
The sorting section allows separation of large contaminates (such as non PET containers
or PET containers with enclosures containing metals) by manual and automatic sorting,
before these contaminates are cut into flakes.
• The manual sorting station uses a horizontal conveyor belt with operator platforms on
either side of the reject discharge chutes. Operators at this station manually pick out
any remaining contamination or non -PET bottles and deposit them into the reject
chutes.
• In the automatic bottle detector section, the bottles are automatically selected by
means of detection technologies and color identification. A compressed air jet ejects
the undesired bottles onto a waste conveyor.
Wet Grinding section.
This section cuts the bottles into flakes, removes liquid contamination and pulverizes re-
sidual paper fiber improving the decontamination process. This size reduction is required
in order to facilitate material handling and chemical effectiveness in downstream sec-
tions.
• Wet Granulator: A grinding machine where water is sprayed into the cutting chamber
with the material. Fewer fines are produced in this machine and any residual paper is
pulped and separated in the washing centrifuge.
Washing Section.
The machines in this section are designed to accept the dirty flake, thoroughly wash it in
a controlled chemical reaction, remove residual glue, separate other contaminates, rinse
the surface from any residual product, and dry it. The following pieces of equipment are
used in this section:
Stainless steel silos with discharge screws and internal screw type mixer.
• Blends and homogenizes the flake

• Accepts surges from upstream equipment and meters it to the downstream
equipment
Reaction tanks: Stainless steel, insulated vessels with high speed, internal im-
pellers, very accurate level and temperature sensors, and discharge pumps.
• Aggressively wash all flake under strict control of the essential parameters
(pH, chemicals liquid -solid ratio, time and temperature)
• Dissolve all glue and pulp all paper residue
• Specially developed impellers promote flake -to -flake contact rather than
flake to machine contact in order to reduce wear.
• A water collection, filtering, and chemical treating loop captures, controls
and reuses the used chemical solution.
Horizontal centrifuge:
• Economically removes liquid, fines and pulp from the flake without allowing
the material to cool. This prevents the dissolved glue from re -adhering to the
machines and flake, which is especially important for higher quality end
product and machine functionality.
Separation tank:
This large tank of water has a bottom discharge with flow control, paddles
across the top, and a material inlet under the surface. Residual floating polymers
(PE and PP) are removed in this machine.
• The material inlet under the surface of the water prevents attached air or sur-
face tension from affecting the buoyancy of the material.
• A patented diffuser at the material entrance insures that the flakes are dis-
persed throughout the tank, thereby minimizing one flake affecting the
buoyancy of another.
• A water filtering and collection system facilitates control of the water
Rinsing reactors:
Highly agitated tanks with a clean water circulation system and extraction
pumps.
• Clean water rinses and cools material for an extremely high quality, clean
product.
Dewatering and drying:
This section consists of a vertical centrifuge and fluid bed drier.
Aerodynamic separation and blending silos
This section removes any fines or film from the multilayer bottles as well as any
polystyrene (PS) or PET labels that may be present.
Big bag unit: The dried and separated flakes are then sent to a big bag filling
station that uses anefficient shaking system to ensure the bags are filled to

/9-T feelbt--)
maximum capacity and weight control. From this packaging operation the
flakes will be shipped by truck.

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0.039 MGD
A Ito
01 0.002 MGD
0.003 MGD
Potable
Water
Chillers
0.02 MGD
0.02 MGD
0.0026 MG
Sanitary
0.005 MGD
DTF Process
DAK Process
f Lid5
is)
i �l
Sluoae
0.073 MGD
0.052 MGD
Slowdown 0.0333IvMGD
0.146 MGD Softener
0.112 MGD
0.228 MGD
Boilers
0.014 MGD
Cooling
Tower
Derain Water
Slowdown 0.01 MGD
0.021 MGD
0.001 MGD
►
Slowdown 0.0004 MGD
Process
0.001 MGD
Steam 0.039 MGD
0.016 MGD
Wastewater
Treatment Plant
A
0.184 MGD
Atmosphere
Blowdown 0.044 MGD
0.1109 MGD
Recycle
Bottle Plant
0.5429 MGD from PWC
0.111 MGD
Fire
Ponds
AI 0.014 MGD
Atmosphere, line testing
Water Balance
DAK Americas LLC
Cedar Creek Site
With Recycle Bottle PIa°
Stormwater 0.050 MGD
Outfall 001
0.094 MGD
Al
To atmosphere
0.012 MGD
Outfall 002
0.291 tV1GD
To Cape Fear River
12/9/2008
EMW

Rr%�0-/RFA)7 C
Lopez, Dale
From: Lopez, Dale
Sent: Friday, September 17, 2010 10:56 AM
To: Corporon, Joe
Cc: Henson, Belinda; Lawyer, Mike; Rawls, Paul
Subject: FW: DAK Cedar Creek - NC0003719
Attachments: image003.jpg
Hi Joe,
Yesterday afternoon Paul Rawls and I visited DAK. According to the Donald Allbright (WWTP ORC) and to my
observation, the Cooling Tower Blowdown (CTW-BD) appeared to flow into and mix with stormwater in the DAK storm
drain system that flowed approximately/2 mile to the Outfall 001. The CTW-BD was at a rate of between 157,000 GPD
to 281,000 GPD on different days during this week. (Just for interesting information, according to DAK's computer
records, there was zero GPD discharge during certain cold winter months).
Let me know if you need additional information.
Thanks,
Dale
From: Henson, Belinda
Sent: Thursday, September 16, 2010 10:01 AM
To: Brantley, Mark; Rawls, Paul; Lopez, Dale; Lawyer, Mike
Subject: FW: DAK Cedar Creek - NC0003719
From: Corporon, Joe
Sent: Wednesday, September 15, 2010 11:38 AM
To: [e-mail]
Cc: Poupart, Jeff; Henson, Belinda
Subject: DAK Cedar Creek - NC0003719
Ms. Wike - I received your phone message Monday asking about permit requirements to convert an aeration basin into
a digester. If not already done, please share your intentions with the Fayetteville Regional Office (FRO). Because this is a
major modification to your treatment system, you will need to:
1. Submit an application requesting a "major modification" and appropriate fees (see our website).
2. Submit an application for Authorization to Construct (A to C) permit, including plans and specification, to
DWQ's Construction Grants and Loans (CG&L).
3. After construction but before operating new facilities, submit an Engineer's Certification form testifying that
construction was conducted in accord with plans & specs, the NPDES permit, and the A to C permit. This may
also require you to inform the FRO to schedule appropriate onsite inspections prior to discharge.
Finally, I understand that your Outfall 001 was incorrectly assumed to be stormwater, and we should therefore remove
it from Stormwater NCS000389 and reinstate it in the subject NPDES permit. Please confirm for me that Outfall 001 has
no stormwater component and is cooling water only. If so, we may consider this in the permit modification along with
the above -proposed changes.
Joe R Corporon, L.G.
Environmental Specialist
1

Lopez, Dale
y i 7 c (c")-)
From: Lawyer, Mike
Sent: Thursday, September 16, 2010 1:44 PM
To: Henson, Belinda; Brantley, Mark; Rawls, Paul; Lopez, Dale
Subject: RE: DAK Cedar Creek - NC0003719
Attachments: image001.jpg
If the outfall in question receives both stormwater AND general wastewater, then discharges from this outfall would be
considered as wastewater and should be captured under the facility's NPDES wastewater permit or a separate
NCG500000 general wastewater permit (I don't see a reason for them to have separate wastewater permits if it can be
captured under one). There may be scenarios where stormwater discharges from the outfall during rain events and
there is no cooling tower blowdown at the same time, which would make these discharges stormwater only. However, it
seems as though the Stormwater Permitting Unit is uncomfortable with covering this outfall under the stormwater
permit as there is no way to be certain if any residual wastewater might be present in the outfall from previous cooling
tower blowdown events. Simply put, if there is any commingling of stormwater with wastewater, then it is all
wastewater.
Mike
Michael Lawyer, CPSWQ
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
e-mail: [e-mail] (please note my current e-mail address)
*E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Henson, Belinda
Sent: Thursday, September 16, 2010 10:04 AM
To: Lawyer, Mike; Brantley, Mark; Rawls, Paul; Lopez, Dale
Subject: FW: DAK Cedar Creek - NC0003719
Mike,
Give me your thoughts on the Stormwater issue. Thanks.
Belinda
From: Elizabeth M. Wike [mailto:ewike©dakamericas.com]
Sent: Wednesday, September 15, 2010 1:03 PM
To: Corporon, Joe
Cc: Poupart, Jeff; Henson, Belinda; Penny Mahoney; J. Anthony Hudson; Donald R. Allbright
Subject: RE: DAK Cedar Creek - NC0003719
i

• Mr. Corporon,
(ce,±)
1. DAK is proposing to convert an existing aeration basin, Aeration Basin #2, to a digester. There is no construction
required, it would just be valved differently than the present configuration, so I it is unclear why we would need an ATC
permit or why this would be considered a major permit modification. Please explain.
2. With regard to outfall 001, this outfall discharges both stormwater and cooling tower blowdown. It was previously
permitted under the sites, NPDES permit, then permitted under the sites stormwater permit. However the stormwater
permit requires DAK to certify that the outfall is "Stormwater Only", something that we cannot do. The stormwater
group said that the NPDES permit needed to be modified to include Outfall 001.
If you need additional information, please call me.
Elizabeth Wike
Environmental Engineer
DAK Americas LLC
P.O. Box 2260
Leland, North Carolina 28451
Office: [phone]
Mobile: [phone]
Fax: [phone]
[e-mail]
From: Corporon, Joe [mailto:[e-mail]]
Sent: Wednesday, September 15, 2010 11:38 AM
To: Elizabeth M. Wike
Cc: Poupart, Jeff; Henson, Belinda
Subject: DAK Cedar Creek - NC0003719
Ms. Wike - I received your phone message Monday asking about permit requirements to convert an aeration basin into
a digester. If not already done, please share your intentions with the Fayetteville Regional Office (FRO). Because this is a
major modification to your treatment system, you will need to:
1. Submit an application requesting a "major modification" and appropriate fees (see our website).
2. Submit an application for Authorization to Construct (A to C) permit, including plans and specification, to
DWQ's Construction Grants and Loans (CG&L).
3. After construction but before operating new facilities, submit an Engineer's Certification form testifying that
construction was conducted in accord with plans & specs, the NPDES permit, and the A to C permit. This may
also require you to inform the FRO to schedule appropriate onsite inspections prior to discharge.
Finally, I understand that your Outfall 001 was incorrectly assumed to be stormwater, and we should therefore remove
it from Stormwater NCS000389 and reinstate it in the subject NPDES permit. Please confirm for me that Outfall 001 has
no stormwater component and is cooling water only. If so, we may consider this in the permit modification along with
the above -proposed changes.
Joe R. Corporon, L.G.
Environmental Specialist
NPDES Program
2

/41 f TgCNfYlENT
tD
DA .Request for Permit Modification
• In addition to renewing the permit, DA.K requests that Outfall SW-1 be added to
the permit. Stormwater and non -contact cooling water are discharged through this
outfall. The DMRs-for this outfall for January 2008 through -March 201-1-are...-
included in this application package. Please note that di-n-butyl phathlate has
been consistently below the level of quantification. Lead and Nickel have either
been below the level of quantification or very nearly at the level of quantification
and well below the cutoff concentrations as defined in the old permit. DAK
Americas requests that the testing requirements for these parameters be dropped
from the permit.
The request to include Outfall SW-1 is necessary because it was not included
when the permit was last renewed. At that time DENR decided to have the
NPDES permit include only the wastewater outfall and move the stormwater
outfalls from permit NC0003719 to the stormwater permit NCS000389. Under
the most recently issued permit for NCS000389, Outfall SW-1 was not included
because it contains cooling tower blowdown, not just stormwater. In discussions
with Brian Lowther, he said that the department felt it best to include SW-1 in the
wastewater permit instead of in the stormwater permit. Joe Corporon advised to
DAK to request this modification when the permit came up for renewal.
DAK will continue to test Outfall SW-1 according to the permit requirements
defined in permit No. NC0003719 which expired on October 31, 2006 until this
issue can be resolved.

A ! T/!C H/bJEg T E ri,d-)
DAK Outfall 001 = MH 1= S W 1
Date
Nickel (µg/L)
Lead (µg/L)
Di-N-Butyl Phthalate (µg/L)
Mar23,2011
<5
0.5
<4.75
Feb 23, 2011
< 5
2.8
< 4.78
Jan24
<5
1.3
<6.45
Dec 17, 2010
< 5
6.8
< 50.1
Nov 23
6.0
0.7
Oct 27
< 5
0.6
< 5.04
Sept 15
7.0
0.7
< 4.83
Aug 18
< 5
0.9
< 4.86
July 21
< 5
0.3
< 4.93
Jun 23
7.0
0.4
< 4.79
May 26
< 5
1.1
< 4.75
Apr 22
<5
0.5
<4.73
Mar 22
6.0
4.0
< 5.22
Feb 17
< 5
3
< 6.09
Jan 27, 2010
< 5
0.3
< 5.36
Dec 1, 2009
< 5
0.5
< 5.19
Nov4
<5
3.0
<6.19
Oct21
<5
0.4
<5.64
Sep 23
<5
0.5
<7.35
Aug27
<5
<3
<5.16
Jul 15
< 5
0.2
< 5.05
Jun25
<5
0.2
<5.23
May 27
< 5
0.5
< 5.26
Apr30
<5
3.0
<5.93
Mar25
<5
<3
<5.16
Feb25
<5
0.5
<5.14
Jan 21, 2009
5.0
< 3
< 5.68

DAK Outfall 002 Fecal Coliforms
Date
Colonies per 100 mL
Feb 23, 2011
1,420
Feb 16
21,400
Feb 9
1,400
Feb 2
8,950
Jan 26
18,000
Jan 19
1,970
Jan 12
909
Jan 5, 2011
200
Dec 29, 2010
2,800
Dec 22
6,000
Dec 15
700
Dec 8
9,850
Dec 2
6,150
Nov 24
11,550
Nov 17
3,350
Nov 11
115
Nov 3
340
Oct 27
274
Oct 20
105
Oct 14
141
Oct 6
> 420
Sept 29
338
Sept 22
4
Sept 15
5
Sept 8
9
Aug 25
76
Aug 18
58
Aug 11
88
Aug 4
2
July 28
13
July 21
7
July 14
23
July 7
2

DAK Americas
FIBERS, MONOMERS & RESINS
April 26, 2011
Mrs. Carolyn Bryant
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Permit Renewal and Modification
NPDES Permit No. NC0003719
Dear Mrs. Bryant:
MAY 0 5 2011
1
DENR-WATER QUALITY
POINT SOURCE BRANCH
The NPDES permit for the Cedar Creek Site of DAK Americas LLC expires on October
31, 2011. DAK Americas is submitting this application package to renew the NPDES
permit for the Cedar Creek Site.
The facility includes DAK's polyester resins manufacturing operations, DuPont Teijin
Films manufacturing operations, Clear Path Recycling LLC, and a Services Complex that
provides utilities to the entire site.
In addition to renewing the permit, DAK requests that Outfall SW-1 ed to the
permit. Stormwater and non -contact coolin water are s isc i arged through this outf I.
have cached a spreadsheet that shows the analytica resu is reported on Rs for this
outfall for 2009-2011. Please note that di-n-butyl phathlate has been consistently below
the level of quantification. Lead and Nickel have either been below the level of
quantification or very nearly at the level of quantification and well below the cutoff
concentrations as defined in the old permit. DAK Americas requests that the testing
requirements for these parameters be dropped from the permit.
The request to include Outfall SW-1 is necessary because it was not included when the
permit was last renewed. At that time DENR decided to have the NPDES permit include
only the wastewater outfall and move the stormwater outfalls from permit NC0003719 to
the stormwater permit NCS000389. Under the most recently issued permit for
NCS000389, Outfall SW-1 was not included. In discussions with Brian Lowther, he said
that the department felt it best to include SW-1 in the wastewater permit instead of in the
stormwater permit. Joe Corporon advised to DAK to request this modification when the
permit came up for renewal.
DAK will continue to test Outfall SW-1 according to the permit requirements defined in
permit No. NC0003719 which expired on October 31, 2006 until this issue can be
resolved.
DAK Americas LLC
32 16 Cedar Creek Road • PO Box 1690 (28302) • Fayetteville, NC 28312
910-433-8300 • fax: [phone]
www.dakamericas.com

If you have any questions, please call Elizabeth Wike at [phone].
Sincerely,
• 1
Craig Leite
Cedar Creek Site Manager

s
Introduction
DAK Americas LLC (DAK) operates an industrial manufacturing facility in Fa-
yetteville,North.Carolina-hiCumberland-County.—Itis-located south -of Highway 53 (Ce-
dar Creek Road) and approximately two miles east of Interstate 95. The site is located in
the Cedar Creek Industrial Complex. The complex also houses DuPont Teijin Films;
Clear Path Recycling LLC; Wellman, Inc. (no longer in operation); and the DAK Service
Complex (a utilities facility purchased from Monsanto in January 2004).
The DAK Resins Plant manufactures polyester pellets that are used in the plastic
container market. The polyester chips are manufactured in a continuous process which
utilizes two primary process systems. The manufacturing operations occur in the south-
west portion of the property in the continuous polymerization (CP) and the solid state po-
lymerization (SSP) plant. The manufacturing process is completely automated and is
controlled from a central control room. Raw materials and catalysts are continuously fed
into a series of continuous polymerization vessels to produce polyester resin. The resin is
extruded and cut into 1/8" cube pellets. The pellets then undergo another heat treatment
phase to produce the desired polymer properties. The finished product is shipped by rail
to customers.
The Services Complex is located east of the DuPont Teijin film property and sup-
plies utilities for both the DAK Resins Plant and the DuPont Teijin Film Plant. Utilities
include steam, cooling water, chilled water, demineralized water, and wastewater treat-
ment.
Wastewater discharges from the facility are regulated under the National Pollutant
Discharge Elimination System (NPDES). DAK is currently operating under NPDES
permit number NC0003719.
DAK is authorized to discharge from one final outfall (002) directly to the Cape Fear
River. The stormwater outfall (001), which includes non -contact cooling water, mixes
with Outfall 002 as it enters the river. The outfall line is submerged and extends ap-
proximately 80 feet offshore. The discharge depth of the outfall pipe is approximately 20
feet below the surface.
In 2010 Clear Path Recycling LLC built a recycle bottle facility to produce up to 90
MM lb/year of clean clear bottle flake and 30 MM lb/year of clean colored bottle flake
from post -consumer PET bottles coming from municipal collection, landfill sorting, curb-
side collection or "deposit systems". The plant is designed for a continuous operation,
twenty fours hours per day, seven days a week.
The recycling process at the Cedar Creek Site involves a number of mechanical and
aqueous separation and wash steps to recover polyethylene terephthalate (PET) flake
from recovered containers (i.e., bottles). Bottles are received in bales and stored outdoors
in a concreted area. All recycling operations will be located inside two existing ware-
house buildings. The system uses multiple lines in some of the process stages to achieve

the design processing rates. For example, there are two wash lines and twin lines for bale
breaking, sorting, and flaking (or grinding). In fact, there is a supplemental grinder that
will be used during start-up for clear product, but converted to the lower -volume colored
flake when in full production. Single line processing is used for clean clear flake, after
the flake is produced and stored. A smaller post -flaking line is used for colored material.
This application package includes EPA Form 1, EPA Form 2C, and other supporting
documents.
(")

Description of Manufacturing Processes
DuPont- Teijin-Films
The DuPont Batch Plant was constructed in 1975 and uses dimethyl terephthalate
(DMT) and ethylene glycol (EG) as the basic raw materials. The Batch Plant produces
primarily film grade polyethylene terephthalate (PET) but small quantities of other spe-
cialty polymers are also produced in the batch reactors.
Ten reactor trains are used for the batch esterification and polymerization processes.
EG and EG prepared with process catalysts and additives are mixed with DMT in the es-
terinterchange reactor where the polymerization process is initiated. This reaction is •
conducted in two stages, the first at atmospheric pressure and the second under vacuum.,
During the esterification step, methanol is generated and removed from the process. The
methanol is collected and returned to the DMT manufacturer for recycle. Upon comple-
tion of the esterification step, the mixture is transferred by pressure into another vessel
for polymer addition where the polymer chain is lengthened. The PET polymer from this
process is extruded, quenched and cut into chips which are transferred to silos for storage
prior to shipment to customers.
Crude EG, which is recovered from the esterification and polymerization, processes
is purified by the batch process in two distillation columns. This recovered EG is then
reused to make additional PET.
DAK Resin Plant
Continuous Polymerization (CP) Plant
The CP Plant was constructed in 1995 and started up in January 1996. Raw materi-
als for the continuous process include terephthalic acid (TA), EG, and isophthalic acid
(IPA). EG is combined with TA and IPA to make a slurry, which is fed to the esterifier
where it is heated to make an oligorner. The oligomer is transferred to the polymeriza-
tion, and polymerization takes place in several steps involving additives and heat. In the
final stages of polymer finishing, the polymer is filtered, extruded, quenched, chipped,
dried and sent as polymer chips to the Solid State Process (SSP).
Solid State Process (SSP)
The SSP involves heating the PET chip to modify the polymer chain. Upon comple-
tion of the SSP, the chips are placed in silos prior to shipment to customers.

•
r,
Supporting Activities
The above facilities also generate wastewater which does not come in contact with
process contaminants. These non -contact streams include demineralized water treatment
blowdown, boiler blowdown, and cooling tower blowdown. In addition, there are sani-
tary waste streams which are routed to the biological treatment system. Other contribu-
tions to wastewater include scrubber effluent, laboratory activities, wash down from
maintenance activities such as steam cleaning of equipment and minor leaks from equip-
ment being repaired. For general housekeeping purposes and to clean residual amounts
of minor leaks and spill, various areas of the plant are periodically washed by spraying
them down with water. This water is routed through a process area chemical sewer to the
biotreatment system.
Wellman
Operations at the Fayetteville Wellman plant ceased in 2003.
Clear Path Recycling LLC
In 2010 Clear Path Recycling LLC built a recycle bottle plant that is capable of pro-
ducing 90 MM lb/year of clean clear flake and 30 MM lb/year of clean colored flake.
Bottle Storage
Bottles will be received in bales and stored outdoors on receiving pads and inside
trailers.
Debailing section
Inside existing warehouses the recycling process begins with debailing.
The aim of this section is to break the bottle bales and to grant a regular flow in line feed-
ing.
• Inclined conveyor belt: The feed end is sunk into the floor so that the entire bales can
be slid onto it. Bales are set on the ground next to the feed section where the wires
are cut and tied to a stationary fixture. The bottles are then pushed with a forklift onto
the belt. The conveyor belt is sized to store bales. This design allows the operator
time to perform other functions as well as loading the conveyor.

a
IIot pre -washing Section
The patented pre -washing section removes the large and abrasive contaminates in a con-
tinuous form. This is accomplished using slow moving machines with very few moving
parts. This section recycles water from the flake washing section that would otherwise be
discharged -as waste:—
• The hot pre- washing removes almost all paper labels
• This section uses a stainless steel jacketed and insulated cylinder, where the loose bot-
tles are mixed with a hot caustic solution of water from the washing system to release
the label from the bottle
• This section also removes all major dirt, sand and glass from the outside of the bot-
tles.
Inspection table and metal sorting .
The sorting section allows separation of large contaminates (such as non PET containers
or PET containers with enclosures containing metals) by manual and automatic sorting,
before these contaminates are cut into flakes.
• The manual sorting station uses a horizontal conveyor belt with operator platforms on
either side of the reject discharge chutes. Operators at this station manually pick out
any remaining contamination or non -PET bottles and deposit them into the reject
chutes.
• In the automatic bottle detector section, the bottles are automatically selected by
means of detection technologies and color identification. A compressed air jet ejects
the undesired bottles onto a waste conveyor.
Wet Grinding section.
This section cuts the bottles into flakes, removes liquid contamination and pulverizes re-
sidual paper fiber improving the decontamination process. This size reduction is required
in order to facilitate material handling and chemical effectiveness in downstream sec-
tions.
• Wet Granulator: A grinding machine where water is sprayed into the cutting chamber
with the material. Fewer fines are produced in this machine and any residual paper is
pulped and separated in the washing centrifuge.
Washing Section.
The machines in this section are designed to accept the dirty flake, thoroughly wash it in
a controlled chemical reaction, remove residual glue, separate other contaminates, rinse
the surface from any residual product, and dry it. The following pieces of equipment are
used in this section:
Stainless steel silos with discharge screws and internal screw type mixer.
• Blends and homogenizes the flake

•
• Accepts surges from upstream equipment and meters it to the downstream
equipment
Reaction tanks: Stainless steel, insulated vessels with high speed, internal im-
pellers, very accurate level and temperature sensors, and discharge pumps.
• Aggressively wash all flake under strict control of the essential parameters
(pH, chemicals liquid -solid ratio, time and temperature)
• Dissolve all glue and pulp all paper residue
• Specially developed impellers promote flake -to -flake contact rather than
flake to machine contact in order to reduce wear.
• A water collection, filtering, and chemical treating loop captures, controls
and reuses the used chemical solution.
Horizontal centrifuge:
• Economically removes liquid, fines and pulp from the flake without allowing
the material to cool. This prevents the dissolved glue from re -adhering to the
machines and flake, which is especially important for higher quality end
product and machine functionality.
Separation tank:
This large tank of water has a bottom discharge with flow control, paddles
across the top, and a material inlet under the surface. Residual floating polymers
(PE and PP) are removed in this machine.
• The material inlet under the surface of the water prevents attached air or sur-
face tension from affecting the buoyancy of the material.
• A patented diffuser at the material entrance insures that the flakes are dis-
persed throughout the tank, thereby minimizing one flake affecting the
buoyancy of another.
• A water filtering and collection system facilitates control of the water
Rinsing reactors:
Highly agitated tanks with a clean water circulation system and extraction
pumps.
• Clean water rinses and cools material for an extremely high quality, clean
product.
Dewatering and drying:
This section consists of a vertical centrifuge and fluid bed drier.
Aerodynamic separation and blending silos
This section removes any fines or film from the multilayer bottles as well as any
polystyrene (PS) or PET labels that may be present.
Big bag unit: The dried and separated flakes are then sent to a big bag filling
station that uses an efficient shaking system to ensure the bags are filled to

v
maximum capacity and weight control. From this packaging operation the
flakes will be shipped by truck.
(oRk)

0.039 MGD
A.
0.002 MGD
Potable
Water
0.02 MGD
0.02 MGD
0.0026 MG
Chillers
0.003 MGD
anitary
0.005 MGD
DTF Process
DAK Process
Sludge
0.016 MGD
0.073 MGD
D
0.052 MGD
Blowdown 0.033 MGD
0.146 MGD Softener
0.1109 MGD
Slowdown 0.0004 MGD
Demin Water
Wastewater
Treatment Plant
A
0.112 MGD
Slowdown 0.01 MGD
Recycle
Bottle Plant
Boilers
0.021 MGD
4
0.001 MGD
Process
4
0.001 MGD
Steam 0.039 MGD
e
0.111 MGD
0.184 MGD
Atmosphere
Slowdown 0.044 MGD
0.014 MGD
Atmosphere, line testing
0.5429 MGD from PWC
Water Balance
DAK Americas LLC
Cedar Creek Site
With Recycle Bottle Pla°
Stormwater 0.050 MGD
Outfall 001
0.094 MGD
To atmosphere
0.012 MGD
Outfall 002
0.291 MGD
y
To Cape Fear River
12/9/2008
EMW

n
Fig:
12/09/2008
DAK Americas Cedar Creek Site Wastewater Treatment Syst
Recycle Bottle Plant
Influent from process
I DAK Resins
I Screening
I Influent from process 1
I Equalization I
I Dupont Teijin Film I
I Neutralization I
I Screening 1
PAK Resins, LLC I
3216 Cedar Creek Road
Payoftavillo_ NC
,rcumberland County!
NPDES Permit No. NC0003719
I Equalization Tanks I
( Non -contact cooling water
Non -contact
cooling water
to stormwater
Outfatl 001
Stormwater !
4
1
Outfall001 J
Outfall002
[Spill Basin I
To Cape Fear River
Effluent from wastewater
treatment plant
DAF
Sanitary
Sewer
pH pit I
l To sludge storage

Regulatory and Permitting Background
Applicable Effluent Guidelines
Organic Chemicals, Plastics,
and Synthetic Fibers
(OCPSF)
40 CFR 414, Subcate-
gory D
Thermoplastic
Resins
DuPont
Organic Chemicals, Plastics,
and Synthetic Fibers
(OCPSF)
40 CFR 414, Subcate-
gory D
Thermoplastic
Resins
DAK