NC0000892_Fact Sheet_20230324

DENR/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES PERMIT NC0000892
Facility Information
Applicant/Facility
Name:
Arclin USA, LLC
Applicant Address:
790 Corinth Road; Moncure, NC 27559
Facility Address:
790 Corinth Road; Moncure, NC 27559
Permitted Flow:
0.1 MGD Outfall 001
Type of Waste:
Industrial/filters & softener backwash/RO
reject/domestic/stormwater
Stormwater:
Outfall 002, Outfall 003, Outfall 004
Facility/Permit Status:
Class II /Active; Renewal
County:
Chatham County
Miscellaneous
Receiving Stream:
Haw River
Stream Classification:
WS IV
Subbasin:
03-06-07
Index No.
16-(42)
Drainage Area mil :
1689
HUC:
03030002
Summer 7Q10 cfs
40 (Regulated flow)
303 d Listed?
No
Winter 7Q10 (cfs):
(Regulated flow)
Regional Office:
Raleigh
30Q2 (cfs)
(Regulated flow)
State Grid / USGS
Quad:
E22SE
Moncure, NC
Average Flow (cfs):
1780 (Regulated flow)
Permit Writer:
Sergei Chernikov,
Ph. D.
IWC (%):
0.39%
Date:
11/21/2022
BACKGROUND
Arclin USA, LLC (formerly Dynea) is an OCPSF (organic chemicals, plastics, and synthetic fibers)
facility. Arclin manufactures thermosetting synthetic resins (including urea formaldehyde resin,
phenol formaldehyde, and melamine formaldehyde resins) for use by the wood products industry.
This facility is listed under SIC codes 2821 (synthetic resins) and 2869 (industrial organic resins).
For process wastewater requirements only 40 CFR 414 Subpart E and Subpart I effluent limits are
applicable, as the process wastewater from the formaldehyde manufacturing process is completely
recycled and not discharged.
The facility does not use any designated process per 40 CFR 414 Appendix A that generate
chromium -bearing, copper -bearing, cyanide -bearing, lead -bearing, or zinc -bearing waste streams.
However, it does use a designated process that generates nickel -bearing waste stream.
This permit is a combined permit for industrial and stormwater discharges to the Haw River, a
controlled discharge from Jordan Lake, in the Cape Fear River Basin. Section A is for requirements
for industrial wastewater through Outfall 001 and Section B is for requirements for stormwater
through Outfalls 002, 003, and 004.
The same permitting strategies for Middle Cape Fear discharges as applied in the previous renewal
will continue, including nutrient monitoring, a reopener condition to allow additional monitoring,
and no increase in nutrient loading until a TMDL has been adopted. The stream segment 2,400 feet
downstream from Outfall 001 continues to be impaired for high pH and exceedance of chlorophyll
a standard.
Fact Sheet
NPDES NC0000892
Page 1 of 5

Section A:
OUTFALL 001
Outfall 001 is the combined wastewater from the plant wastewater treatment facility and from the
reverse osmosis (RO) unit, 80% is treated wastewater and 20% is RO reject wastewater. The
current permit wastewater influent flow is 46,000 gpd. The domestic wastewater influent flow to
the plant wastewater facility is defined as 2,000 gpd.
TREATMENT PROCESS
Except for the RO reject wastewater all other sources of plant wastewater are collected in an
equalization basin (EQ). The EQ wastewater continues to the aeration basin, then to the clarifier,
and then mixes with RO reject water before discharging to Outfall 001. Solids are sent to drying
beds and are removed from the beds 3-4 times a year by a compost contractor.
COMPLIANCE
During the previous 5 years the facility violated permit limits 3 times: 1 BOD violation in 2017
and 2 phenol violations in 2022.
PERMITTING STRATEGY
The renewal application was used to determine the process waste water flow of 0.046 MGD. Limits
as defined in 40CFR 414 Subpart E and Subpart I effluent guidelines were calculated accordingly.
Table below summarizes the effluent limits calculations for BOD and TSS.
Calculation of BOD and TSS limits for Outfall 001
40 CFR 414.51 Subpart I: 0.070 (MGD) x factor (mg/L) x 8.34 = mass limit (lbs/day)
BOD
TSS
Monthly Avg
Daily Max
Monthly Avg
Daily Max
Factor, m L
61
163
67
216
Mass, lbs/day
35.6
95.2
39.1
126.1
Secondary standards: 0.002 (MGD) x factor (mg/L) x 8.34 = mass limit (lbs/day)
Monthly Avg
Daily Max
Monthly Avg
Daily Max
Factor, mg/L
30
45
30
45
Mass, lbs/day
0.50
0.75
0.50
0.75
40 CFR 414.51 mass limit + Secondary standards mass limit = Outfall 001 mass limit
Monthly Avg
Daily Max
Monthly Avg
Daily Max
Outfall 001, lbs/da
36.1
95.95
39.6
126.85
The facility confirmed it does not use the EPA listed processes (40 CFR 414 Appendix A) that
generate chromium, copper, cyanide, lead, and zinc waste, and are thus is not subject to Subpart I
requirements for chromium, copper, cyanide, lead, and zinc. A comparison of Subpart I effluent
limitations to known WQS were conducted. Hexachlorobenzene, Benzo(a)pyrene, and 1,2,4-
Trichlorobenzene will have a more stringent Daily Maximum WQS-based limit.
REASONABLE POTENTAL ANALYSIS
The Division conducted EPA -recommended analyses to determine the reasonable potential for
toxicants to be discharged at levels exceeding water quality standards/EPA criteria by this
facility from Outfall 001. For the purposes of the RPA, the background concentrations for all
parameters were assumed to be below detection level. The RPA uses 95% probability level and
95% confidence basis in accordance with the EPA Guidance entitled "Technical Support
Fact Sheet
NPDES NC0000892
Page 2 of 5

Document for Water Quality -based Toxics Control." The RPA included evaluation of dissolved
metals' standards, utilizing a default hardness value of 25 mg/L CaCO3 for hardness -dependent
metals.
Calculations included: Total Polyaromatic Hydrocarbons (PAH), Cr, Cu, Pb, Ni, Zn, and Nitrate
(please see attached). The permit limit of 0.1 MGD was used in the RPA. The analysis indicates
no reasonable potential to violate the surface water quality standards or EPA criteria for all
parameters except PAH.
The proposed permit requires that EPA methods 200.7 or 200.8 (or the most current versions)
shall be used for analyses of all metals except for total mercury.
RO IMPACT
The RO wastewater is not treated and combines with the treated wastewater generating 17% of the
NPDES discharge. To provide data for future evaluation of the RO wastewater impact, the WTP
Strategy was used to assist in defining RO parameters of concern. The following effluent
parameters monitoring will be continued:
1) Salinity
2) Conductivity
3) Total Dissolved Solids
4) Total Arsenic
5) Total Chloride
6) Total Iron
WHOLE EFFLUENT TOXICITY
Current Requirement: Outfall 001 — Chronic P/F @ 0.39 using Ceriodaphnia
Recommended Requirement: Outfall 002 — Chronic P/F @ 0.39% using Ceriodaphnia
This facility has passed all toxicity tests during the previous permit cycle, please see attached.
INSTREAM DATA
The facility is a member of the Upper Cape Fear River Association. Data was obtained for coalition
stations B4080000 (Haw River —1.03 miles upstream from Outfall 001) and B6160000 (Cape Fear
River — 4.30 miles downstream from Outfall 001). The downstream sample point is downstream
from the confluence of Haw River and Deep River.
The data was reviewed for the period of 2016 through 2022. The DO level downstream of the
discharge was violated only once (08/13/2016). The confluence of the Haw River and Deep River
impact the downstream parameters, which makes it very difficult to determine impact from the
facility on the receiving stream.
The facility is inlikely to have a significant impact on the Haw River due to the very low instream
waste concentration (0.39%).
SECTION B: (Permit writer Brianna Young)
OUTFALLS 002, 003, and 004
The current permit has designated stormwater outfalls and was reviewed for compliance with
current stormwater strategies. Stormwater narratives and conditions were updated where warranted
as follows:
Fact Sheet
NPDES NC0000892
Page 3 of 5

1) B. (1) Individual Permit Coverage
New narrative to establish effective and expiration date conditions for stormwater
outfalls, and permit coverage.
2) B. (2) Permitted Activities
New narrative to establish stormwater criterion.
3) B. (3) Stormwater Pollution Prevention Plan
Update to existing permit A. (5) special condition requirements.
4) B. (4) Analytical Monitoring Requirements
New special condition with defined monitoring frequency for next 5 years, new benchmark
Tier narratives, and new monitoring parameters with benchmark values as follows:
a. TSS — 100 mg/L
b. pH — 6 S.U. to 9.0 S.U.
c. NH3-N — 5.6 mg/L (Summer)
NH3-N — 15.0 mg/L (Winter)
d. Formaldehyde - 0.5 mg/L
e. BOD5 — 30 mg/L
f. COD — 120 mg/L
g. Oil & Grease — 30 mg/L
h. Total Nitrogen (TN) - 30 mg/L
i. Total Phosphorus (TP) — 30 mg/L
j. Total Rainfall — monitor only
5) B. (5) Qualitative Monitoring Requirements
Update to existing permit A. (6) special condition requirements.
6) B. (6) On -Site Vehicle Maintenance Monitoring Requirements
Update to existing permit A. (7) special condition requirements with new benchmarks as
follows:
a. pH — 6 S.U. to 9 S.U.
b. Non -polar Oil & Grease by EPA Method 1664 (SGT-HEM) — 15 mg/L
c. TSS — 100 mg/L
d. Total Rainfall — monitor only
e. New Motor Oil Usage — monitor only
SUMMARY OF PROPOSED CHANGES
• The new electronic reporting requirement was added to the permit based on the EPA
Rule.
• The total PAH limit was added to the permit based on the results of the Reasonable
Potential Analysis.
• The limits for OCPSF parameters, BOD, and TSS were recalculated based on the latest
production data.
• The new PFAS Special Condition was added to the permit to implement EPA's PFAS
Guidance.
• The Stormwater Section of the permit was updated.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: January 8, 2023
Permit Scheduled to Issue: March 13, 2023
Fact Sheet
NPDES NC0000892
Page 4 of 5

NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit for
Outfall 001, please contact Sergei Chernikov at [phone] or email
[e-mail]
If you have questions regarding any of the above information or on the attached permit for
Outfalls 002, 003, and 004, please contact Brianna Young at [phone] or email
[e-mail].
CHANGES IN THE FINAL PERMIT
1. The PFAS Monitoring was increased from Annually to Quarterly to meet the requirements
of the EPA's PFAS Guidance.
2. The limits for OCPSF parameters, BOD, and TSS were recalculated based on the updated
flow of 0.07 MGD due to increase in production since the original renewal application
was submitted in 2016.
The Division is unable to increase the flow limit above 0.01 MGD. In order to increase the
flow limit the facility shall submit a completed Engineering Alternatives Analysis (EAA),
required by 15A NCAC 021-1.0105 (c) (2).
3. The Division provided 30-day comment period required by the state rules. The Public Notice was
published on the DWR site on January 10 and the comments were requested to be submitted by
February 13.
Fact Sheet
NPDES NC0000892
Page 5 of 5