NC0000892_Response to NOV-2022-MV-0135_20221129

Akin
Performance Applied
November 21, 2022
Vanessa Manuel — Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1617 Mail Service Center
Raleigh, NC 27699-1611
RE: Notice of Violation NOV-2022-MV-0135
Arclin USA, LLC
NPDES Permit Number NC0000892
Chatham County
Dear Ms. Manuel:
On November 15, 2022, Arclin USA, LLC in Moncure, Chatham County, North Carolina
received the above -referenced Notice of Violation (NOV) for the August 11, 2022 waste water
formaldehyde analysis that was not recorded on the monthly Discharge Monitoring Report, (but
was noted on the DMR as missing due to the sample being lost by Pace Analytical Laboratory
during their shipment to their sub -contract laboratory). See the attached letter from Pace
Analytical Laboratory explaining the missing analyses as well as the chain of custody showing
the wastewater samples were transferred from Arclin and received by Pace Analytical
Laboratory.
The letter from Pace Analytical Laboratory acknowledges wastewater samples collected were
picked up at Arclin-Moncure by Pace Analytical, and taken to the Pace Analytical Laboratory in
Raleigh, NC. The samples were logged in at the Pace -Analytical Raleigh Lab, and then shipped
to AES-Atlanta for formaldehyde analysis. When we received the laboratory report Arclin
inquired about the missing analysis and was informed that the samples were missing. .By the time
Arclin learned of the missing samples, it was too late to collect additional samples to meet permit
monitoring requirements.
Arclin requested that Pace Analytical Laboratory conduct an investigation into the missing
samples. The result of the Pace Analytical investigation: AES Lab claimed they could not fmd
the regulatory formaldehyde samples (2 containers).
Arclin believes the lost samples were beyond our control, and therefore, the Notice of Violation is
not warranted.Arclin respectfully requests that the NCDEQ formally withdraw the Notice of
Violation. If you concur, please provide Arclin with a written notice of withdrawal of the Notice
of Violation.
If you have questions concerning this submittal, please feel free to contact Bowman Harvey at
[phone].
Sincerely,
J#mes Gard
Plant Manager

aceAnalytical
PIWATOWSISININ
November 18, 2022
Arclin-Dynea
790 Corinth Rd
Moncure, NC 27759
RE: Permit Required Formaldehyde test results for August 2022 sampling event
Mr. Lamm,
This is a letter of explanation on what happened to the formaldehyde result for the August 2022
sampling event.
On August 11, Pace courier picked up samples at the Arclin-Dynea site in Moncure, NC. All compliance
samples were processed and logged in at Pace's Raleigh NC laboratory/service center including the
required formaldehyde sample.
Formaldehyde analysis is performed by AES Labs in Atlanta, GA. The sample was shipped via FedEx from
Pace Raleigh to AES Atlanta. No samples were left in Raleigh lab and were packed in cooler to AES.
Samples were shipped and once Pace received the laboratory report realized that there were no results
forArclin-Dynea formaldehyde analysis.
AES could not find the sample and, therefore, we have no results for the formaldehyde compliance
sample for August 2022. This is a lab error and we are changing procedures to ensure this does not
happen again. First, we will require AES to email Pace the login information once the samples have
been logged in. Turnaround times will be shorter so if there is any lost samples/lab error, client can re -
sample within monthly requirement. Managerial level oversight will be provided on Arclin-Dynea's
monthly sampling. The customer service manager will be overseeing the login and receipt of Arclin-
Dynea's samples.
I sincerely apologize on Pace's behalf. Please do not hesitate to contact me if you have any further
questions.
Sincerely,
Kelly Wallace
Account Executive

Pace Analytical

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