NC0000892_2023 Compliance Evaluation Inspection_20240108

January 8th, 2023

James Gard
Arclin USA Inc.
790 Corinth Road
Moncure, NC 27559

Subject: Compliance Evaluation Inspection
Arclin USA Inc.
NPDES Permit NC0000892
Chatham County

Dear Mr. Gard:

On Thursday, December 28th, 2023, Kevin Fowler conducted a compliance evaluation inspection
of the treatment systems located at Arclin USA Inc. Moncure plant. The purpose of this visit
was to conduct an inspection of the subject NPDES facility. During the inspection, the presence
and cooperation of Crhistopher Lamm, Operator in Responsible Charge (ORC), and Bowman
Harvey, the HSE manager for the plant, were helpful and appreciated.

The Arclin USA Inc. Moncure plant, located at 790 Corinth Road, Moncure, North Carolina
27559 in Chatham County. The plant has a Industrial Process & Commercial Wastewater
Discharge permit.

This NPDES compliance evaluation inspection consisted of the following:
 Review of the NPDES permit;
 Review of the owner/facility information;
 Review of April 2022 – December 2023 monitoring data.
 Review of April 2022 – December 2023 compliance history.
 On-site inspection of the treatment systems; and
 On-site inspection of discharge outfalls and storm water outfalls.

DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
Page 2 of 3
Arclin USA Inc. – Moncure Plant
Compliance Inspection 2024
2
Findings during the pre-inspection file review were:

1. Through NPDES permit NC0000892, Arclin USA Inc. is authorized to discharge treated
wastewater from the Moncure Plant to the Haw River, classified WS-IV waters in the Cape
Fear River Basin. The current NPDES permit was issued effective May 1, 2023, and will
expire April 30, 2028. An application for renewal of this permit should be submitted no less
than six months before the expiration of the current permit.
2. Arclin provides treatment and discharge of wastewater through outfall pipe 001 to the Haw
River. The plant is permitted to discharge at a rate of 0.1 MGD. The system consists of: an
aerated equalization (EQ) basin with surface aerators, active sludge aeration basin with
surface aerators, secondary clarifier, sludge drying beds, effluent flow meter and composite
sampler.
3. The NPDES permit also includes a requirement for the permittee to develop and implement a
stormwater pollution prevention plan. Outfalls 002, 003, and 004 are designated as
stormwater outfalls.
4. For the review period April 2022 – December 2023, one violation was found for the
exceedance of limits in whole effluent toxicity testing. No civil penalty assessment was
issued for this violation.

Findings during the inspection were:

5. The operator’s log and supporting analytical documentation were consistent and up to date.
6. DMR reports from June 2023, and February 2023 were brought to be compared to laboratory
analytical results. No discrepancies were found.
7. The Facility had seven sludge drying beds (four 20 ft x 50 ft ones and three 25 ft x 50 ft
ones). The facility does not have tertiary sand filters. Wasted sludge is injected and mixed
with polymer before being placed on the beds. Dried sludge is placed in a covered storage
area and is hauled off for composting by McGill Composting.
8. Domestic sewage is pumped to the EQ basin from a simplex pump station. Audible and
visual alarms are present at this station. An overflow line to the EQ is also present in the
case of pump failure.
a) Process water is also pumped to the EQ basin from a separate pump station. This station
contains one main pump and one backup pump.
9. EQ basin had three surface aerators. Wastewater is pumped from the EQ basin to the
aeration basin with a back up overflow line if needed. The aeration basin also contains three
surface aerators. At the time of the inspection, the DO in the aeration basin was at 8.6 mg/l,
which was higher than needed.
10. At the time of the inspection, the EQ and Aeration Basin were near max capacity. The ORC
indicated that during times of high flow they are able to manage by moving water through the
system faster. He indicated that they are still able to meet permit requirements during these
times.
11. Mixed liquor from the aeration basin is pumped to the secondary clarifier, polymers are fed
to facilitate the settling of solids. At the time of inspection, sludge blanket was normal (1
foot in the 8 feet deep clarifier).
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
Page 3 of 3
Arclin USA Inc. – Moncure Plant
Compliance Inspection 2024
3
12. The right of way to Outfall 001 was well maintained. Visual inspection of the outfall was not
possible the day of the inspection due to high river levels because of recent rain events. The
right of way to Outfall 002, 003, and 004 were well maintained as well. No evidence of
solids or visible environmental impacts were noted downstream of the effluent pipe from
outfall 002, 003, and 004..

If you have questions or comments about the inspection, this report or the requirements to take
corrective action (if applicable), please contact Kevin Fowler at 919-437-0047 or via email at
[e-mail]

Sincerely,

Vanessa Manuel
Water Quality Regional Assistant Supervisor
Raleigh Regional Office

Attachments: EPA Water Compliance Inspection Report

Cc: Laserfische
Christopher Lamm (ORC)
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N 52 NC0000892 23/12/28 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Arclin USA, Inc
790 Corinth Rd
Moncure NC 27559
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
09:00AM 23/12/28 23/05/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Christopher G. Lamm/ORC/919-542-2526/
Other Facility Data
12:30PM 23/12/28 28/04/30
Name, Address of Responsible Official/Title/Phone and Fax Number
Bowman Harvey,790 Corinth Rd Moncure NC 27559/HSE Manager/919-545-5753/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Kevin Fowler DWR/RRO WQ/919-791-4200/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
12/29/2023
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
NPDES yr/mo/day
23/12/28
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
NC0000892 17
Page#2
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
Permit:NC0000892
Inspection Date:12/28/2023
Owner - Facility:
Inspection Type:
Arclin USA, Inc
Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Facility analyzes mixed liqour suspende solids, temperature, pH, DO, and sludge
blanket for process controls.
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Permit Expires April 2028.Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Drying Beds Yes No NA NE
Is there adequate drying bed space?
Is the sludge distribution on drying beds appropriate?
Are the drying beds free of vegetation?
# Is the site free of dry sludge remaining in beds?
Is the site free of stockpiled sludge?
Is the filtrate from sludge drying beds returned to the front of the plant?
# Is the sludge disposed of through county landfill?
# Is the sludge land applied?
(Vacuum filters) Is polymer mixing adequate?
Comment:
Pump Station - Influent Yes No NA NE
Page#3
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
Permit:NC0000892
Inspection Date:12/28/2023
Owner - Facility:
Inspection Type:
Arclin USA, Inc
Compliance Evaluation
Pump Station - Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Process influent pump station has one main pump and one back up. A Simplex pump
station pumps domestic sewage into EQ basin. There are overflow bypass lines to EQ
basin in case of pump failure. Audible and visual alarm located on domestic simplex
pump station.
Comment:
Equalization Basins Yes No NA NE
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Three surface aerator/mixers present. There is an overflow bypass line from EQ to
aeration basin. Basin did not have much freeboard space due to heavy rain recently.
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Page#4
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
Permit:NC0000892
Inspection Date:12/28/2023
Owner - Facility:
Inspection Type:
Arclin USA, Inc
Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth)
Sludge blanket was about one foot.Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Surface
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin’s surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/l)
One surface aerator was turned off. DO was 8.6 mg/L.Comment:
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Indicated that facility is currently searching for a new lab for bio-assay.Comment:
Chemical Feed Yes No NA NE
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Polymer is fed to mixed liqour before entering clarifier. Polymer is injected into wasted
slude before being placed on drying beds.
Comment:
Page#5
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
Permit:NC0000892
Inspection Date:12/28/2023
Owner - Facility:
Inspection Type:
Arclin USA, Inc
Compliance Evaluation
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment:
Pumps-RAS-WAS Yes No NA NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Page#6
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558
Permit:NC0000892
Inspection Date:12/28/2023
Owner - Facility:
Inspection Type:
Arclin USA, Inc
Compliance Evaluation
Record Keeping Yes No NA NE
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
ORC visitation logs are both kept in a note pad as well as a excel spread sheet print
off.
Comment:
Page#7
DocuSign Envelope ID: 4236625C-2CE8-487D-8F6C-EF4EFBB0A558