NC0000892_Comments_20230324

A-rdin
Performance Applied
February 13, 2023
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: ArclinUSA,LLC—Moncure,NC
DRAFT NPDES Permit Renewal - Comments
Permit Number NCO000892
Dear Sergei Chemikov:
The Arclin USA, LLC Plant located at 790 Corinth Road in Moncure, NC received the DRAFT NPDES
Permit for review on January 25 (draft permit dated January 10, 2023) with request for comments by
February 13, 2023. Arclin is providing the following comments concerning Draft NPDES Permit
NCO000892.
1. The limits calculated for OCPSF parameters, BOD and TSS need to be revised. Theflowrateused
to calculate the limits was 0.046 MGD. This flow was from 2015 data submitted in our February
2016 permit renewal application and listed on Form 2C. Our production has increased over the last
seven years since that submission and the new permit limits need to reflect that and should reflect
our anticipated production throughout the life of the permit.
The following are the past data and the new projections. Production information is considered
confidential and should not be disclosed to the public.
Year
Annual Production, LBS
Average Effluent Flow, MGD
2015
397,750,268
0.049
2022
550,982.498
0.070
2027 (estimated)
999,460,394
0.127
Increase from 2015 to 2027, %
152
159
2. Based upon this the OCPSF parameters, BOD and TSS should be revised using the 0.127 MGD flow
estimate for 2027 to provide limits through the life of the permit. In addition, the flowrate should be
increased to 0.2 MGD.
3. NC DEQ has only allowed 19 calendar days to comment on this draft permit. We could not find the
regulation on the mandatory comment period but they are usually at least 30 days. We request NC DEQ
to provide the statutory time requirement for comments and an explanation if 19 days meets that
requirement.
If you have any questions concerning this submittal, please feel free to contact Bowman Harvey at (919)
545-5753.
r1aill. IVIMIdgri
RECEIVED
FL3 -15 2@23
NCDEO/DWR/NPDES