NC0003719_Engineering Alternatives analysis_20080229

NPDES DOCUMENT !PCANNIN. COVER SHEET
NC0003719
Cedar Creek site WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
February 29, 2008
This document is printed on reuse paper - igriore any
content on the re'rerse side

DAK Americas
FIBERS, MONOMERS & RESINS
February 29, 2008
Ms. Toya D. Fields
NPDES Western Permitting Unit
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RECEIVED
t, R - 5 2005,
Subject: Request for Additional Information UA�ITY
DAK Americas, LLC — Cedar Creek Plant DENR , WATER 0
Application NC0003719 RA
Cumberland Cumberland County POINT SOURCE B
Dear Ms. Fields,
We have reviewed your letter of January 3, 2008 related to the Engineering Alternatives
Analysis (EAA) dated August 2004. The purpose of this letter is to respond to these
comments.
Your comments can be summarized into three general issues, so we have organized our
response around these three issues.
Issue 1 -- Plant Flows
You noted that flows at the wastewater treatment plant at our Fayetteville site have
decreased since the original EAA was completed and requested that we base our cost
comparisons on more current flows.
Table 1 shows effluent flows for 2007, by month, at the plant.
Table 1
2007 Effluent Flows by Month
Month
Flow (MGD)
Jan
0.212
Feb
0.243
Mar
0.172
Apr
0.176
May
0.131
Jun
0.173
Jul
0.145
Aug
0.180
Sep
0.218
Oct
0.133
Nov
0.106
Dec
0.181
Avg
0.173
DAK Americas LLC
3500 Daniels Road, N.E. • Leland, NC 28451
1-877-432-2766
www.dakamericas.com

The average daily flow was 173,000 gallons per day. Because of changes in our
operations and water conservation, this flow is significantly less than that used in our
2004 report which was based upon 2003 flow data. Later in this letter, we provide
revised estimates of operations and maintenance costs and have used these lower flows in
these estimates.
Issue 2 — Basis for Load Estimates
You noted that the EAA is not clear as to what flow basis was used for BOD and TSS
calculations for Alternative #3. You asked that we provide more information on those
load estimates and recalculate, if necessary, based on more recent flow and/or
operational data. DWQ prefers that actual 2006 or 2007 data be used.
Influent BOD is not measured at the plant. However, influent COD is measured. We
have used a conversion factor of 0.53 to convert COD to BOD. This factor is based on
results of a wastewater characterization study performed at another DAK Americas
facility in Moncks Comer, South Carolina. The facility has comparable production and
wastewater characteristics. Table 2 summarizes the BOD calculation for 2007.
Table 2
Influent COD and BOD
COD
Mass (lb/day)
BOD5
Mass (lb/day)
Jan
3375
1789
Feb
4210
2231
Mar
3675
1948
Apr
3299
1748
May
3677
1949
Jun
3552
1883
Jul
3839
2035
Aug
4443
2355
Sep
3507
1859
Oct
2838
1504
Nov
3167
1679
Dec
4381
2322
Avg.
3664
1942
Issue 3 — Costs for Alternatives Discharging to PWC
Your comments note that by sending wastewater to PWC, DAK Americas' effluent would
not have to be treated to such a high degree as with a continuing surface discharge.
Therefore, would not the operations and maintenance costs under Alternatives 4 and 5 be
less than that for Alternatives 2 and 1, their direct discharge counterparts? Similarly,
would not the upgrade cost for Alternative 4 be less than that for Alternative 2?

Table 4
(Comparable to Table 4-3 From EAA)
Present Worth of Costs
Alternative
1
2
4
5
Capital Cost
$0
$960,000
$960,000
$0
O&M Cost
$644,773
$590,878
$686,821
$727,242
Present Worth of Costs
$8,121,148
$8,402,321
$9,610,756
$9,159,876
You noted in that the capital cost for Altemative 4 may be less than the $960,000 that is
estimated for Alternative 2. Possibly. However, if we were to use a capital cost of only
$500,000 for the upgrade under Alternative 4 rather than $960,000, this would decrease
the present worth of costs for that alternative to $9,150,756 which is still considerably
higher than the costs for Alternatives 1 or 2.
Despite significant changes in some of the operations and maintenance costs in response
to your comments, Alternatives 1 and 2 which include continued direct discharge from
DAK Americas' Cedar Creek Wastewater Treatment Plant, have similar present values,
and remain the lower cost altematives.
We have attempted to be fully responsive to the comments contained in your letter.
Should you have any additional questions or concerns, please do not hesitate to contact
me.
Respectfully submitted,
DAK Americas
X,611(3) Jr)/
Elizabeth M. Wike
Copies: Penny Mahoney-DAK Americas
Nick Hatala, Stearns & Wheler
9 v

You also requested that we correct or explain the following discrepancies:
• Electricity costs for alternatives #2 and #4 are different. The text of the EAA
argues they should be the same;
• Materials and maintenance costs for #2 and #4 are different. The text of the EAA
argues they should be the same;
• Administrative costs for #4 are lower than the other alternatives.
In recent years, DAK Americas has successfully decreased the operations and
maintenance costs at the Cedar Creek WWTP. Rather than using the O&M costs from
the EAA, which were based upon 2003 data, we have completely revised the O&M costs
to use the actual 2007 figures as the base. Therefore, Alternative 1, No Upgrades and
Maintain NPDES Permit, reflects 2007 O&M costs.
We have not prepared new "bottoms up" estimates of capital and O&M costs for the
additional alternatives. However, based upon your comments, we have performed
sensitivity analysis on the life cycle costs based upon reasonable assumptions of changes
in capital and O&M costs. If, after making these assumptions, the results of the
evaluation changed significantly we would spend the time to develop more definitive cost
estimates. The basis of our revised cost estimates are discussed below.
Alternative 1, No Upgrades and Maintain NPDES Permit —O&M Costs for all
categories except Administrative and Maintenance are based upon actual 2007 costs. We
do not have ready access to current Administrative and Maintenance costs, so we have
used the costs cited in the original EAA for these categories.
Alternative 2, Upgrade Cedar Creek WWTP and Maintain NPDES Permit —We
kept the same capital cost for the upgrade as the original EAA. We decreased electrical
costs by approximately 8 percent to reflect efficiencies from the upgraded plant. We
limited the decrease to 8 percent because of the significant decreases in electrical costs
already realized between 2003 and 2007. We decreased maintenance costs from
$100,000 to $50,000 reflecting fewer repairs and replacements on the upgraded facility.
This is an estimate based solely upon experience and judgment, but we think it is
representative of what might be realized with an upgraded plant.
Alternative 3, Discharge Untreated Wastewater to PWC—We do not consider this
alternative to be technically feasible. The Indirect Discharge Permit issued by PWC to
DAK Americas establishes limits for BOD, TSS, and flow. These limits will be routinely
exceeded without pretreatment of the wastewater. Moreover, the Indirect Discharge
Permit lists several other parameters that must be monitored. If monitoring results
indicate the presence of pollutants in amounts that could cause endangerment, upset,
pass -through, or hinder the operation of the treatment facility in any way, pollutant -
specific limits may be applied. DAK Americas does not wish to risk such a result by
discharging untreated wastewater directly to the PWC system. Moreover, such
arrangements (routine exceedance of pretreatment limits and payment of surcharges)

have been found to be in violation of EPA's regulations. Therefore, we have removed
this alternative from further consideration.
Alternative 4, Upgrade Cedar Creek WWTP and Discharge to PWC-In this
alternative, we would pay for the flow discharged to PWC, so using 2007 figures, we
estimated flow at 173,000 gallons per day at a cost of $3.115 per 1000 gallons.
You have suggested for this alternative and Alternative 5 that we could treat the
wastewater to a lesser standard and further reduce O&M costs. We're not sure about this,
since we need to remove 95 percent of the BOD to meet PWC's relatively low
pretreatment limit of 100 mg/1 for BOD5. However, assuming for the sake of discussion
that we could reduce certain O&M costs by treating to a lesser level, we decreased all of
the variable O&M costs to 75 percent of those in Alternative 2. This 75 percent figure
has no scientific or empirical basis. Consider it to be a reasonable assumption used to
test the sensitivity of our results.
Alternative 5, Discharge Treated Wastewater to PWC Using the same reasoning as
in Alternative 4, we decreased the variable O&M costs to 75 percent of those in
Alternative 1. As in Alternative 4, this alternative includes a cost for the flow to be sent
to PWC.
Table 3
Revised O&M Costs
Alternative 1 2 4 5
Description
No Upgrades
and Maintain
NPDES
Permit
Upgrade Cedar
Creek WWTP
and Maintain
NPDES
Upgrade Cedar
Creek WWTP
and Discharge to
PWC
Discharge
Treated
Wastewater to
PWC
POTW Charge for Flow
200,801
200,801
Electricity
63,895
60,000
45,000
47,921
Maintenance
100,000
50,000
37,500
75,000
Lab Expense
51,445
51,445
51,445
51,445
Administrative
120,000
120,000
120,000
120,000
Nutrients and Misc. Chemicals
20,642
20,642
15,482
15,482
Polymers
86,147
86,147
64,610
64,610
Sludge Disposal
75,500
75,500
56,625
56,625
Steam
127,144
127,144
95,358
95,358
Totals
644,773
590,878
686,821
727,242
Changes in the estimates for annual operations and maintenance costs have an effect on
the present worth calculation. The revised present worth calculation is presented in Table
4. The present worth of costs are based upon a discount rate if 4.875 percent, which is
the current guidance from the Construction Grants and Loans website, and a term of 20
years.

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

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

DAK
Subject: DAK
From: Susan Wilson <[e-mail]>
Date: Mon, 03 Oct 2005 16:40:05 -0400
To: Teresa Rodriguez <[e-mail]>
CC: Gil Vinzani <[e-mail]>
Teresa - got a call from Penny Mahoney at DAK (nc0003719). she said Jeff Richardson
has left the company. i told her you were working on the EAA and many apologies for
us (me!) taking so long.
mostly, she was calling to see if Jeff had ever submitted a permit modification to
remove the NCCW(?) from the process water wastestream (they spoke of this during one
of our meetings). i told her i had not seen anything and didn't see it on our
database.
she'll likely be submitting this soon. she was also talking about her renewal
permit. it's assigned to Toya. we might want to think about trading another
industry that's assigned to you, since you'll have such a familiarity with that one.
anyway...some thoughts to consider.
if you do run across a permit mod (which i doubt you will), give her a ring at
910-371-5232.
thanks!
1 of 1 10/6/2005 3:45 PM

NC DENR - DIVISON OF WATER QUALITY
.0311 CAPE FEAR RIVER BASIN
2B .0300
Name of Stream
Description
Class
Class
Date Index No.
Greens Creek (Holmes Pond)
Evans Lake
CAPE FEAR RIVER
CAPE FEAR RIVER
Cross Creek (Big Cross
Creek) (Texas Pond, Smith
Lake, Rose Lake)
Unnamed Tributary near
Rosehill Road (Country Club
Lake)
Unnamed Tributary near
Rosehill Road
Cross Creek (Big Cross
Creek)
Cross Creek (Big Cross
Creek)
Little Cross Creek (Bonnie
Doone Lake, Kornbow Lake,
Mintz Pond)
Little Cross Creek
(Glenville Lake)
Little Cross Creek
Blounts Creek
Branson Creek (Branson Lake)
Hybarts Branch
Locks Creek
Gum Log Canal
Flat Swamp Ditch
Reece Creek
From source to McPherson
Creek
Entire lake and connecting
stream to Cape Fear River
From a point 0.5 mile
upstream of City of
Fayetteville water supply
intake to City of
Fayetteville water supply
intake
WS-IV,B
WS-IV
WS-IV;CA
From City of Fayetteville C
water supply intake to
mouth of Hammond Creek
From source to a point 0.5 WS-IV
mile upstream of water
supply intake at Murchison
Road in Fayetteville
From source to dam at
Country Club Lake
From dam at Country Club
Lake to Cross Creek
From a point 0.5 mile
upstream of water supply
intake to water supply,
intake at Murchison Road. in
Fayetteville
WS-IV,B
WS-IV
WS-IV;CA
From water supply intake at C
Murchison Road in
Fayetteville to Cape Fear
River
From source to a point 0.5 WS-IV
mile upstream of backwaters
of Glenville Lake
From a point 0.5 mile
upstream of backwaters of
Glenville Lake to dam at
Glenville Lake
From dam at Glenville Lake
to Cross Creek
From
From
From
From
River
source
source
source
source
to Cross Creek
to Blounts Creek
to Branson Creek
to Cape Fear
From source to Locks Creek
From source to Gum Log Canal
From source to Locks Creek
WS-IV;CA
08/03/92 18-24-3-3
08/03/92 18-25
08/03/92 18-(25.5)
04/01/59 18-(26)
08/03/92 18-27-(1)
08/03/92 18-27-2-(1)
08/03/92 18-27-2-(2)
08/03/92 18-27-(2.5)
03/01/77 18-27-(3)
08/03/92 18-27-4-(1)
08/03/92 18-27-4-(1.5)
03/01/77 18-27-4-(2)
03/01/77 18-27-5
03/01/77 18-27-5-1
03/01/77 18-27-5-1-1
07/01/73 18-28
09/01/74 18-28-1
09/01/74 18-28-1-1
09/01/74 18-28-2
Page 35 of 68 2009-04-04 04:35:02

CAPE FEAR RIVER BASIN
Name of Stream
Subbasin Stream Index Number Map Number Class
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER
CAPE FEAR RIVER (excluding
Carltons Mill Run
Carolina Beach Yacht Basin
Carrols Branch (Lake Bay)
Carrs Creek
Cartwheel Branch
Carvers Creek.
Carvers Creek
Carvers Creek (Cypress Lake)
Cary Branch
Castle Mill Creek (Mill Creek)
Caswell Basin
Cat Tail Branch
Caterpillar Creek
Caterpillar Creek
Catfish Creek
Catskin Creek
Cattail Creek
Causey Lake
Cedar Creek
Cedar
Cedar
Cedar
Cedar
Cedar
Cedar
Creek
Creek
Creek
Creek
Creek
Fork
Cedar Snag Creek
Chapel Creek
Cherry Tree Prong
Cherry Tree Swamp
Chinnis Branch
Chocolate Creek
CPF07
CPF13
CPF07
CPF13
CPF14
CPF07
CPF14
CPF15
CPF15
CPF15
CPF1S
CPF16
CPF16
CPF16
CPF16
CPF16
CPF16
CPF17
CPF17
CPF20
CPF17
area described below) CPF17
CPF19
. CPF24
CPF14
CPF13
CPF17
CPF16
CPF16
CPF15
CPF07
CPF18
CPF17
CPF19
CPF04
CPF04
CPF17
CPF23
CPF04
CPF03
CPF10
CPF11
CPF07
CPF07
CPF15
CPF17
CPF06
CPF24
CPF06
CPF17
CPF17
CPF17
CPF03
18-(16.7)
18-(16.7)
18-(20.3)
18-(20.3)
18-(20.3)
18-(20.7)
18-(20.7)
18-(20.7)
18-(23.5)
18-(25.5)
18-(26)
18-(26)
18-(49)
18-(53.5)
18-(58.5)
18-(59)
18-(62.5)
18-(62.5)
18-(63)
18-(63)
18-(71)
18-(87.5)
18-68-2-10-2
18-87-31.2
18-23-13-3
18-20-7
18-72
18-56-(0.3)
18-56-(0.7)
18-24
18-7-5
18-68-12-9
18-88-13
18-68-1-10-2
16-27-6-(1)
16-27-6-(2)
18-69
18-74-49-2-1
16-31-2
16-19-3-2
17-26.5
17-39
18-11-(1)
18-11-(2)
18-33
18-88-8-2-4
16-41-1-15-2-3
18-87-17
16-41-2-8
18-70-2
18-81-6-1-5-1
18-66-5-1
16-19-8-1-1
F23NE8
F23NE8
F24SW5
F24SWS
F24SWS
F24SW5
F24SW5
F24SW5
G24NW4
G23SE1
G23SE4
G23SE4
I25SW4
I25SW8
J2SNE8
J2SNE8
J26SW1
J26SW1
J26SW1
J26SW1
J27SW7
L27NW1
H26NW6
K27SW6
G21NE5
F22NE4
J26SE9
J2SNW2
J25NW2
G23NW6
E23SW2
H25NW7
L26NE9
G25SE8
D21NE3
D22NW4
J26SE6
J28NW1
D21SES
C20SW7
F2ONE3
E21SES
F23NW1
F23NW1
H24NW3
L27NW7
D22NE3
J28SW4
D22NE9
J26SE5
K26NW9
J26SW9
D20NE1
Ws -Iv
WS-IV
WS-IV;CA
WS-IV;CA
WS-IV;CA
WS-V
WS-V
WS-V
WS-IV
WS-IV;CA
C
C
WS-V
WS-IV
WS-IV;CA
WS-IV;Sw
WS-IV;Sw,CA
WS-IV;Sw,CA
C;Sw
C; Sw
SC
SA;HQW
C;Sw
SB
WS-III
C
SC;Sw
C
WS-IV
WS-IV,B
c
C;Sw
SC
C;Sw
WS-II;HQW,NSW
WS-II;HQW,NSW,CA
C;Sw
C;Sw
C;NSW
WS-IV;NSW
C;HQW
C
C
WS-IV
C
SA;HQW
B;NSW
SA;ORW
WS-IV;NSW
C; Sw
C; Sw
C;Sw
C;NSW
Page 6 of 31
2009-04-04 04:37:38

PRODUCT AND PRODUCT GROUP DISCHARGES
SUBJECT TO EFFLUENT LIMITATIONS AND STANDARDS
for the
ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS
POINT SOURCE CATEGORY - 40 CFR 414
April 2005
Office of Water
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, D.C. 20460

Plastics (Resins)e
Phenolic resins (continued):
Phenol - Formaldehyde, rosin modified
(Rosin Resins)
Phenol - Resorcinol - Formaldehyde
Phenol-Terpene (polyterpene)
Resorcinol - Formaldehyde
Phenoxy resins
Polyacetal (Acetal resin, Polyoxymethylene)
Polyamides (aliphatic)
Dimer acid -based polyamide
Epichlorohydrin-based polyamide
Nylon 6
Nylon 9
Nylon 11
Nylon 12
Nylon 66
Nylon 6/12
Polyaramides (ar = aromatic)
Polyacrylic acid
Polybutadiene
Polybutenes (Polybutylene)
Polybutene-1
Polybutenylsuccinic anhydride
Polycarbonate
Polyester resins, saturated
Polybutylene terephthalate (PBT)
(polytetramethylene terephthalate)
Polyethylene terephthalate (PET)
PET as film
PET, as bottle -grade resins
PET, as plastic bottles
Polyalkylene isophthalate
Polyoxybenzoate
Subpart' Remarks,Tradenames`, Cross-references
E*
E*
E*
E*
D**
[E] Tradenames: Celcon, Delrin.
Classified in commerce as a Thermoplastic
Resin (Subpart D).
D
D* Tradenames:lsonamid
D*
D Tradenames: Capron, Dymetrol, Elvamide,
D* Ertalon, Felor, Fosta, Herox, Milvex,
D Moleculoy, Platamid, Texalon, Tynex,
D Versalon, Vydyne, Vylor, Wellamid,
D Well -blend, X-tal, Xylon.
D
D Tradenames: Kevlar
[D] See Acrylic acid. Regulated in OCPSF as a
PLASTIC, but classified in commerce as an
organic chemical.
[D] OCPSF not applicable, if previously reported
as an elastomer under SIC 2822 (414.11c).
D
D*
D
D Tradenames: Calibre, Lexan, Merlon.
D
D Tradenames: Celanx, Gafite, Gaftuf, Valox,
VCT.
D*
X*
D*
X*
D*
D
OCPSF not applicable. Regulated by
40 CFR 463 (414.11d) and reported under
SIC 3081. Tradenames: Cronar, Mylar,
Estar, Melinex, Scotchpak, Scotchpar.
Tradenames: Kodapak, Cleartuf.
OCPSF not applicable. Regulated by
40 CFR 463 and reported under SIC 3085
(414.11 d).
Tradenames: Advaco
23

Plastics (Resins)a
SAN (Styrene + Acrylonitrile)
Silicone resins
Silicone rubbers
Triazone resins:
Acetoguanamine-Formaldehyde
Benzoguanamine-Formaldehyde
Urea resins
Urea -Formaldehyde (Methylol)
Urea -Melamine -Formaldehyde
Subpart'
D
[D]
[D]
E*
E*
E
E
E*
Remarks,Tradenames`, Cross-references
See ABS resins.
Classified in commerce as Thermosetting
Resins (Subpart E).
OCPSF not applicable (414.11d). Regulated by
40 CFR 428.30 and reported under SIC 2822.
Tradenames: Aerolite, Amres, Cascamite,
Casco -Resin, Catabox, Fabroz, Foundrez,
Fporka, Foundrez, Fporka, Kaurit, Polyria,
Resamin, Resimene, Styplast, Syn-U-Tex,
Uformite.
Vinyl polybutadiene X* OCPSF not applicable (414.11d). Regulated by
40 CFR 428.30 and reported under SIC 2822.
Vinyl resins (unspecified) D*
Vinyltoluene resins D See Polyvinyltoluene copolymers
Explanatory Notes and Footnotes for Table 2-6
Footnotes:
a. Listing of Plastics (Resins) adapted from:
(1) Tables III and IV in Vol. II, Appendix III -A, Final Development Document for Effluent
Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic
Fibers. EPA 440/1-87/009, October 1987.
(2) OCPSF Product/Process File compiled by the Engineering & Analysis (formerly
Industrial Technology) Division of EPA's Office of Science & Technology (formerly
Water Regulations & Standards), 1976-1983.
(3) SRI Directory of Chemical Producers, 1986 Edition, pp. 908-934.
b. Subpart notations:
D = Subpart D, Thermoplastic Resins, 40 CFR Part 414.40.
E = Subpart E, Thermosetting Resins, 40 CFR Part 414.50.
[ ] = Indicates a change in the status of a product since promulgation of the OCPSF regulation.
These include changes in product classification prompted by published amendments to the
OCPSF regulation, and corrections for errors in the listings of products in Table V, VI or VII of
the OCPSF Development Document.
X = OCPSF regulation is not applicable to the product.
* = The product was not listed in Table III or IV in the OCPSF Development Document, or in FR
52, Nov. 5,1987, pp. 42572-42574. These additional products were selected from those shown in
the 1986 SRI Directory of Chemical .Producers.
27

Original permit:
Modified permit:
A.(1-2) From effective date of permit-
September 30, 2002
A.(1-2.) From March 1, 2002 to
January 31, 2003
A.(3.-4) From October 1, 2002-expiration date
of permit (October 31, 2006)
A.(3-4) From February 1, 2003- expiration
date of permit (also October 31, 2006)
A(.9.) From effective date of permit-
Sept. 30, 2002
A.(9.) From March 1, 2002 to January 31, 2003
A.(10.) From October 1, 2002- expiration date
of permit
A.(10.) From February 1, 2003 to expiration
date of permit
Monsanto (NC0003719) compliance schedule

Cost Summary —
V✓1", , i.r
#1- No changes
#2- Upgrade plant
#4-Upgrade and
#3- Discharge influent to discharge effluent to
PWC PWC
#5- Discharge
effluent to PWC
without upgrade
Electricity
$ 275,940.00
$
59,130.00
$
- $
98,550.00
$ 275,940.00
Nutrients
$ 30,000.00
$
30,000.00
$
- $
30,000.00
$ 30,000.00
Chemicals
$ 195,896.00
$
100,000.00
$
- $
100,000.00
$ 195,896.00
Lab Expense
$ 156,000.00
$
156,000.00
$
156,000 $
156,000.00
$ 156,000.00
Sludge disposal
$ 130,031.25
$
114,062.50
$
- $
114,062.50
$ 130,031.25
Maintenance and Materials
$ 100,000.00
$
50,000.00
$
- $
75,000.00
$ 100,000.00
Administrative
$ 120,000.00
$
120,000.00
$
120,000 $
100,000.00
$ 120,000.00
POTW flow trtmnt - 100%
$ -
$
-
$
480,340 $
480,340.00
$ 480,340.00
POTW BOD trtmnt - 80%
$ -
$
-
$
362,013 $
-
$ -
POTW peak BOD trtmnt - 20%
$ -
$
-
$
231,943 $
-
$ -
POTW peak TSS trtmnt -20%
$ -
$
-
$
24,492 $
-
$ -
% more than cheapest
more than status quo
1,007,867
60%
0%
629,193 $
0%
-38%
1,374,787 $
119%
36%
1,153,953 $
83%
14%
1,488,207
137%
48%
REVISED Cost Summary (Staff notes)
#1- No changes
#2- Upgrade plant
#4-Upgrade and
#3- Discharge influent to discharge effluent to
PWC PWC
#5- Discharge
effluent to PWC
without upgrade
Electricity
Nutrients
Chemicals
Lab Expense
Sludge disposal
Maintenance and Materials
Administrative
POTW flow trtmnt - 100%
POTW BOD trtmnt - 80%
POTW peak BOD trtmnt - 20%
POTW peak TSS trtmnt -20%
TOTAL COST
% more than cheapest
% more than status quo
275,940.00
30, 000.00
195,896.00
156,000.00
130,031.25
100,000.00
120,000.00
1,007,867
60%
0%
629,193
0%
-38%
59,130.00 $ $
30,000.00 $ $
100,000.00 $ - $
156,000.00 $ 156,000 $
114,062.50 $ - $
50,000.00 $ - $
120,000.00 $ 120,000 $
$ 283,739 $
$ 362,013 $
$ 231,943 $
$ 24,492 $
$ 1,178,186 $
87%
17%
59,130.00
30,000.00
100,000.00
156,000.00
114, 062.50
50, 000.00
100, 000.00
283,739
892,931
42%
-11%
275,940.00
30, 000.00
195, 896.00
156,000.00
130, 031.25
100, 000.00
120,000.00
283,739 -b ' ` '
rofkliv\icil— ocr ji
1,291,606 1� Z Li(
105% I (747'l i m)
28%

„t"
id

14
Description
Units
Unit Cost
Alternative 1
YrlyQuantity
Cost
Unit Cost
Alternative 2
Y rlyQuantity
Cost
Unit Cost
Attemative 3
YrtyQuantity Cost
Unit Cost
Alternative 4
YrlyQuantity
Cost
Unit Cost
Alternative 5
YrlyQuantity Cost
Electricity
kWh
$ 0.05
6,132,000
$ 275,940.00
same
1,314,000
$ 59,130.00
same
0 '
$ •
same
2,190,000
$ 98,550.00
same
same $ 275,940.00
Nutrients
LS
$ 30.000.00
1
$ 30,000.00
same
same
$ 30,000.00
$
same
same
$ 30,000.00
same
same
$ 30.000.00
Chemicals
LS
$ 195,896.00
1
$ 195,896.00
$ 100,000.00
same
$ 100,000.00
$ -
5100,000.00
same
$ 100,000.00
same
same
$ 195,806.00
Lab Expense
LS
$ 156,000.00
1
$ 156,000.00
same
same
$ 156,000.00
same
same
$ 156,000.00
same
same
$ 156,000.00
same
same
$ 156,000.00
Sludge disposal
lb
$ 0.25
520,125
$ 130,031.25
same
456.250
$ 114,062.50
$ -
same
456.250
$ 114,062.50
same
same
$ 130,031.25
Maintenance and Materials
LS
$ 100,000.00
1
$ 100,000.00
$ 50,000.00
same
$ 50,000.00
same
0
$ -
$ 75.000.00
same
$ 75,000.00
same
same
$ 100,000.00
Administrative
LS
S 120,000.00
1
$ 120.000.00
Same
same
$ 120,000.00
same
same
$ 120,000.00
$100,000.00
1
$ 100,000.00
same
same
$ 120,000.00
;POTW flow trtmnt - 100%
1,000 gpd
$
$ -
$ 3.29
146,000
$ 480,340.00
same
same
$ 480,340.00
same
same
$ 480,340.00
POTW BOD trtmnt -80%
lbslday
$
$ -
$ 0.31
1,162,160
$ 362,012.84
same
0
$
same
0
$ -
POTW peak BOD trtmnt - 20%
Ibs/day
$ -
$ -
$ 0.31
744,600
$ 231,942.90
same
0
$ -
same
0
$ -
POTW TSS trtmnt - 80%
Ibs/day
$ -
$ -
$ 0.13
0
$ -
same
0
$ -
same
0
$ -
POTW peak TSS trtmnt -20%
Ibs/day
$ -
$
$ 0.13
182,500
$ 24,491.50
same
0
$ -
same
0
$
(41(-,b
0,01i
Miq C, s &
MIA) 9, 0 c(z)
^, Jc7
01 di bir
- lz
d-oo 6
0,s>
(1', 0.
T,(5-
7)14/yi fvf--)b x 36s Sys)

Isa-u 13)E(76/*- /3e-s
0#1- No changes
0#4-Upgrade and discharge effluent to PWC
$1,600,000
$1,400,000
$1,200,000 -
$1,000,000
DAK Americas - Yearly O&M Comparison for Alternatives
(Calculated from EAA Assumptions)
❑#2- Upgrade plant 0#3- Discharge influent to PWC
0#5- Discharge effluent to PWC without upgrade
TA
0 $800,000
U
$600,000 -
$400,000
$200,000
$
"'Taus taake,4,PA
/4-6141,::)e)
11/4%2J -it/a ./i0(,,A.
m m
PI/Pc) ?,
Options #2 and #4 have an additional
$960K project cost.
11
•tl t5 �� 5e �5 Je,, 0\0 0\0 o`0 010 CO"
ti`\o `\oc .er Qeo SQo� `ea �`��` moo �p 20 ��o GO
�o � Geecc‘ ��,+ oar �a \c�5 �` o� •o` �o P.'
5 woe `\0 �o �O ,c5
e <z
o� o
Q Q
Category

0#1- No changes
DAK Americas - Yearly O&M Comparison for Alternatives
(NPDES re -calculations)
0#2- Upgrade plant 0#3- Discharge influent to PWC
0#4-Upgrade and discharge effluent to PWC 1:14#5- Discharge effluent to PWC without upgrade
62,000,000
$1,800,000
$1,600,000
$1,400,000
$1,200,000
p $1,000,000
U
$800,000
$600,000 -
$400,000
$200,000
$-
7r
m m n, rn min
• A
��\G tie 5v�5 oho �oho �0\0 O
ms �Go��do
N.
�``'N ' ' ,0. +QQrnaa��t
e e� P ,,,,'N.'.Opp Opp 5C.°
e a e�
Sao` e& Q0 �Qe �*Q
O QO
4
Category

REVISED Cost Summary (Staff notes) - includes addt'I 960K project cost for options 2 and 4 /,
#1- No changes
#2- Upgrade plant
#4-Upgrade and
#3- Discharge influent to discharge effluent to
PWC PWC
#5- Discharge
effluent to PWC
without upgrade
Electricity
Nutrients
Chemicals
Lab Expense
Sludge disposal
Maintenance and Materials
Administrative
POTW flow trtmnt - 100%
POTW BOD trtmnt - 80%
POTW peak BOD trtmnt - 20%
POTW peak TSS trtmnt -20%
TOTAL COST
% more than cheapest
% more than status quo
275,940.00
30,000.00
195,896.00
156,000.00
130,031.25
100,000.00
120,000.00
1,007,867
0%
0%
59,130.00 $
30,000.00 $
100,000.00 $
156,000.00 $
114,062.50 $
50,000.00 $
120,000.00 $
- $
- $
- $
- $
1,589,193 $
58%
58%
120,000
283,739
362,013
231,943
24,492
1,178,186
17%
17%
$
156,000 $
$
59,130.00
30,000.00
100,000.00
156,000.00
114,062.50
50,000.00
100,000.00
283,739
1,852,931
84%
84%
275,940.00
30,000.00
195,896.00
156, 000.00
130,031.25
100,000.00
120,000.00
283,739
1,291,606
28%
28%

DIVISION OF WATER QUALITY
June 19, 2006
MEMORANDUM
TO: Carolyn Bryant
Point Source Branch
FROM: Dale Lopez, Environmental Specialist
THROUGH: Belinda S. Henson, Regional Sup
SUBJECT: Renewal of NPDES Permit
DAK Americas LLC
NPDES No. NC0003719
Cumberland County
er Prot �c�tion ec ion Fly� �
4it
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.
DL/RM-S
Enclosures
fi
JuN 2 0 2006
�r�;R • WATER QUALITY
•PPE BRANCH

SOC PRIORITY PROJECT: YES NO X
If Yes, SOC No.
To: Permits and Engineering Unit
Water Quality Section
Attention: Carolyn Bryant
Date: June 19, 2006
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 8, 2006
3. Report Prepared by: Dale Lopez, Environmental Specialist FRO
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:
Latitude: 34 deg. 58'8" Longitude: 78 deg. 46' 58"
Latitude: Longitude:
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 bluff between 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 100 yards wide, 8-10 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:
(See attached A)
f. Please provide a description of proposed wastewater treatment facilities: N/A
g.
Possible toxic impacts to surface waters: Waste contains several toxic substances. To
date, treatment levels have effluent passing toxicity requirements. There were two (2)
aquatic toxicity failures at this facility since January 1999 for pimephales promelas:
August 1999 and May 2003. The reasons for the failures were 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.
Residual Contractor:
Telephone:
b. Residuals stabilization: PSRP PFRP Other
c. Landfill: Solids from the drying beds are sent to Sampson County Landfill
d. Other disposal/utilization scheme (specify):
3. Treatment plant classification (attach completed rating sheet):
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: Is currently available to send wastewater to PWC
Rockfish WWTP with an approved pretreatment permit IUP# 2116RF '
Subsurface: N/A
Other disposal options: N/A

5. Other Special Items: DAK is presently a member of the Cape Fear River Assembly and instream
Cape Fear River monitoring is performed by this group, thus upstream and downstream
monitoring by the company should not be a permit requirement.
PART IV - EVALUATION AND RECOMMENDATIONS
The wastewater treatment adequately treats the wastewater generated from DAK Resins Plant and the
Dupont Teijin Film Plant. There is a small increase in production projected for 2007 indicated in the
application package.
Based on our June 8, 2006 site inspection, 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 from the DAK Resins Plant. A questionnaire will be sent to DAK from FRO concerning the
stormwater permit NCS000389 request to modify the NPDES permit to include an additional outfall:
outfall 003 as the stormwater runoff from the DAK Resins Plant (See Attachment B).
Signature of Report Preparer
19
oe.&eleft. 5,,41&007‘.
Water Quality Regional Suiso
Date

Incorporation of NCS000389 requirements into NC0003719
Subject: Incorporation of NCS000389 requirements into NC0003719
From: Aisha Lau <[e-mail]>
Date: Wed, 14 Jun 2006 11:15:26 -0400
To: [e-mail]
CC: Toya Fields <[e-mail]>
Hello Mike,
I just got off of the phone with Toya, and she hasn't had a chance to look over the
renewal package yet. She will be looking into if there are any potential roadblocks
for that particular site and circumstances, and will get back to you after she knows
more, later this week or next. She will also let you know what, if any, additional
information the DAK representatives will have to submit to pursue this option.
I know that in the past when I have incorporated general wastewater permit
requirements into individual stormwater permits I have needed some correspondence
requesting the change and the rescission of the permit that is being incorporated.
But whether that is even necessary or what type of correspondence that needs to be is
up to the unit.
Take care,
Aisha
Aisha Lau N.C. Division of Water Quality Stormwater Permitting Unit 1617 Mail Service
Center Raleigh, NC 27699-1617
Phone: [phone] ext. 578 Fax: [phone] email: [e-mail]
Website: http://h2o.enr.state.nc.us/su/stormwater_html
Never doubt that a small group of thoughtful, committed citizens can change the
world; indeed, it's the only thing that ever has. Margaret Mead
1 of 1 11/22/2006 9:57 AM

DAK Americas
FIBERS, MONOMERS & RESINS
December 5, 2008
RECEIVED
Mrs. Carolyn Bryant DEC 1 2008
North Carolina Department of Environment and Natural Resources
Division of Water Quality ,WATER OUALi'tY
Point Source Branch DENR
1617 Mail Service Center POINT SOURCE BRANCH
Raleigh, NC 27699-1617
Subject: Permit Renewal and Modification
NPDES Permit No. NC0003719
Dear Mrs. Bryant:
The NPDES permit for the Cedar Creek Site of DAK Americas LLC expired on October
31, 2006. On May 3, 2006 DAK submitted an application to renew the permit. To date,
the permit has not been renewed.
The current facility includes DAK's polyester resins manufacturing operations, DuPont
Teijin Films manufacturing operations, and a Services Complex that provides utilities to
the entire site.
DAK Americas plans to build a recycle bottle facility that will, when completed produce
up to 90 MM lb/year of clean clear bottle flake and 30 MM lb/year of clean colored bottle
flake. This application package, which includes EPA Form 1, EPA Form 2C, and other
supporting documents, updates the application submitted in 2006 to reflect the proposed
changes. DAK Americas requests that the existing NPDES permit be modified to add the
recycle bottle plant to the operation at the Cedar Creek Site.
After obtaining the modified NPDES permit, DAK will submit an application for an
Authorization -to -Construct permit to upgrade the wastewater treatment plant. This
information has been compiled and presented in order to facilitate a thorough and timely
review by the Division of Water Quality.
Sincerely,
Craig Leite
Cedar Creek Site Manager
P.O. Box 1690 / Fayettevi:le, N.C. 28302 / 910-433-8200 / www.ciakamericas.com

Introduction
DAK Americas LLC (DAK) operates an industrial manufacturing facility in
Fayetteville, North Carolina in Cumberland County. It is located south of Highway 53
(Cedar Creek Road) and approximately two miles east of Interstate 95. The site is lo-
cated in the Cedar Creek Industrial Complex. The complex also houses DuPont Teijin
Films; 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
polymerization (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 via the
railroad 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) mixes with Outfall 002 as it enters the river. The
outfall line is submerged and extends approximately 80 feet offshore. The discharge
depth of the outfall pipe is approximately 20 feet below the surface.
DAK Americas plans to build 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. It will create twenty to thirty new jobs in Cum-
berland County.
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 will be received in bales and stored out-
doors on receiving pads and inside trailers. All recycling operations will be located inside
two existing warehouse 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 supple-
mental 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, which includes EPA Form 1, EPA Form 2C, and other
supporting documents, updates the application submitted in 2006 to reflect the proposed
changes. DAK Americas requests that the existing NPDES permit be modified to add the
recycle bottle plant to the operation at the Cedar Creek Site. The Engineering Alterna-
tives Analysis for this site has been previously submitted. The conclusions in the EAA
do not change with the construction of the recycle bottle facility.
After obtaining the modified NPDES permit, DAK will submit an application for an
Authorization -to -Construct permit to upgrade the wastewater treatment plant.

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 com-
pletion of the SSP, the chips are placed in silos prior to shipment to customers.

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.
Recycle Bottle Facility
DAK Americas plans to build a recycle bottle plant that will produce 90 MM lb/year
of clean clear flake and 30 MM lb/year of clean colored flake. The plant is currently be-
ing designed and it is anticipated that construction will take six to eight months to com-
plete once environmental permits are received.
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
feeding.
• Inclined conveyor belt: The feed end is normally 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.

Hot 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
bottles are mixed with a hot caustic solution of water from the washing system to re-
lease 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
maximum capacity and weight control. From this packaging operation the
flakes will be shipped by truck.

Wastewater Treatment System Operation
Present Operating Status
The wastewater collection and treatment network consists of the following key sys-
tems: Outfall 001 for stormwater 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 the DAK Americas Resin Plant and the DuPont
Teijin Film Plant. 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 and the DuPont Teijin Film Plant travel
through separate lines into either of two Equalization (EQ) Tanks. These Equaliza-
tion 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 by-
passes EQ tanks for the pH Control Pit. The only other wastewater treated is domes-
tic sewers from the DAK Services Complex that directly enter the biological aeration
basin.
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
in the first chamber to adjust the pH. Uran and phosphoric acid are also added in the
first chamber as nutrients. Defoaming chemicals 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. 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 clarifi-
cation process to remove suspended solids from the treated water. Sometimes the
solids do not settle very well, therefore polymers, Klaraid PC 1224 and IC 1172, are
added at the distribution box where the flow is leaving Aeration Basin 2 and entering
the clarifer to aid in coagulation. This allows for improved settling of solids and less
solids 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. Chlorine tablets are added to the clarifier to
prevent algae growth.
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 Basin
2. The solids from the drying beds are sent to the Sampson County Landfill.

Future Operating Status
The preliminary design for treating the wastewater water from the recycle bottle fa-
cility consists of
1. Coarse Screening utilizing a side hill separator screen.
2. Equalization in a 50,000 gallon tank
3. Neutralization
4. An internally fed rotary wedgewire screen and associated solids dewatering screw
press to dewater and compact solids for ultimate disposal at the landfill.
5. A dissolved air flotation (DAF) unit to remove fine particulate solids. Potential
chemicals may include a flocculent polymer and/or anti -foaming agent.
6. Subsequent biological treatment in the existing wastewater treatment plant.
7. Add approximately 150-hp aeration capacity to the existing aeration basin No. 1.
DAK Americas plans to apply for an Authorization -to -Construct Permit as soon as it
receives the revised NPDES permit.

t
Request for Permit Modification
• Outfall 003 discharges stormwater runoff from the DAK resins plant. This outfall is
currently permitted under NCS000389, a separate stormwater permit. DAK Americas
requests that DENR add this outfall to the new permit and, if added to the new permit,
then to revoke NCS000389. This would consolidate all stormwater outfalls and proc-
ess wastewater outfalls into one permit.
• DAK Americas requests that the NPDES permit be modified to include the wastewa-
ter from the recycle bottle plant.

i
ilk 's jf+)
J-- - - - ' &'-',/[ (-./
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Sub-Basin: 03-06-15
Latitude : 34°58'08"
Longitude: 78°46'58"
Quad#: H23NE/Cedar Creek NC
Stream Class: C
Receiving Stream: Cape Fear River
Permitted Flow: 1.25 MGD (002) and no limit (001)
DAK Americas LLC
Cedar Creek Site
3468 Cedar Creek Road
Fayetteville, NC 28312-8205
)(2&;;
DAK Americas
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FIBERS, MONOMERS & RESINS

o
Table I. D Americ s LLC Cedar Creek Site
O all Loca ons
Outfall
Latitude
Longitude
Description
Receiving Water
Dry Weather Flow
001
34°58"08'
78°46"58'
Stormwater from developed and undeveloped land throughout the plant
property including the plant process areas and cooling tower .
blowdown.
Cape Fear River
Yes
002
34° 58"08'
78°46"58'
Sanitary waste, treated process waste from the utility wastewater,
cooling tower blowdown, boiler blowdown, steam condensate and
sanitary and treated process waste from DuPont Teijin Films.
Cape Fear River
Yes
003
34° 59"02'
78°47"26'
Stormwater from the DAK resins plant. This outfall is currently
permitted under NCS000389. DAK Americas requests that DENR add
this outfall to the new permit and, if added to the new permit, then to
revoke NCS000389. This would consolidate all stormwater outfalls
and process wastewater outfalls into one permit.
Cape Fear River
No
A
34°59"02'
78°46"40'
Stormwater from the parking lot and paved areas where the Monsanto
facility formerly stood. The former Monsanto area will be the bottle
storage yard for the recycle bottle facility. The outfall discharges onto
a vegetative strip prior to entering the waterway.
Cape Fear River
Small amount of
groundwater infiltration
B 1
34°58"58'
78°46"39'
Stormwater from the proposed recycled bottle storage area. The outfall
discharges onto a vegetative strip prior to entering the waterway.
Cape Fear River
No
B2
34°58"56
78°46"38'
Stormwater from the paved roadway used for in -plant transportation.
Stormwater from the proposed recycled bottle storage area. The outfall
discharges onto a vegetative strip prior to entering the waterway.
Cape Fear River
Small amount of
groundwater infiltration
B3
34°58"55'
78°46"38'
Stormwater from the paved roadway used for in -plant transportation.
Stormwater runoff from the proposed recycled bottle storage area. The
outfall discharges onto a vegetative strip prior to entering the
waterway.
Cape Fear River
No
C
34°58"54'
78°46"39'
Stormwater from the railroad spurs used to transport materials.
Stormwater runoff from the proposed recycled plant. Sheet flow only
through a vegetated strip
Cape Fear River
No

)
Outfall
Latitude
Longitude
Description
Receiving Water
Dry Weather Flow
D
34°58"54'
78°46"42'
Stormwater from the railroad spurs used to transport materials.
Stormwater from the proposed recycled plant. Sheet flow only through
a vegetated strip
Cape Fear River
No
E
34°58"49'
78°46"42'
Area drains a small paved area near the proposed recycle bottle plant.
The outfall discharges onto a vegetative strip prior to entering the
waterway.
Cape Fear River
No
F
34°58"42'
78°46"50'
Stormwater from developed and undeveloped land throughout the plant
property including process areas. Overflow from SW001. The outfall
discharges onto a vegetative strip prior to entering the waterway.
Cape Fear River
Small amount of
overflow from SW001
G
34°58"41'
78°46"50'
Stormwater from activities associated with wastewater treatment basins,
fuel oil storage and paved roadways used for in -plant transportation
The outfall discharges onto a vegetative strip prior to entering the
waterway.
Cape Fear River
No
H
34°58"45'
78°47"05'
Stormwater from activities associated with the wastewater treatment
plant. Outfall discharges onto a vegetative strip prior to entering the
waterway.
Cape Fear River
No
Extensive sampling was conducted for all outfalls and submitted with the permit renewal application in 1992. Outfalls A through G indicated low levels or less
than detectable amounts of pollutants. Based on this documentation, the State decided that stormwater sampling would only be required from Outfall 001. For
ease of accessibility, this sample is taken from the manhole designated SW-1, which is immediately upstream from Outfall 001.

'l
0.039 MGD
110
Potable
Water
J
0.02 MGD
0.02 MGD
0.0026 MG;
DTF Process
0.073 MGD
0.002 MGD
0.003 MGD
Chillers
Sanitary
0.005 MGD
DAK Process
0.052 MGD
Blowdown 0.033 MGD
0.146 MGD
0.228 MGD
Softener
Demin Water
Blowdown 0.0004 MGD
ll►
Sludge 1 0.016 MGD
Wastewater
Treatment Plant
0.112 MGD
0.014 MGD
Boilers
Blowdown 0.01 MGD
0.021 MGD
0.001 MGD
Process
0.001 MGD
Steam 0.039 MGD
111 Cooling
Tower
0.1109 MGD Recycle
Bottle Plant
0.111 MGD
Fire
Ponds
0.184 MGD
Atmosphere
Blowdown 0.044 MGD
Alk 0.014 MGD
Atmosphere, line testing
A
0.5429 MGD from PWC
Water Balance
DAK Americas LLC
Cedar Creek Site
With Recycle Bottle Plant
Stormwater 0.050 MGD
Outfall 001
0.094 MGD
To atmosphere
0.012 MGD
Outfall 002
0.291 MGD
To Cape Fear R▪ iver
12/9/2008
EMW

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

K
a
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