NC0024881_Pretreatment - Dystar meeting_20200228

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
February 28, 2020
Mr. Chuck Smith, Public Works Director
City of Reidsville
100 Vance Street
Reidsville, North Carolina 27320
SUBJECT: Pretreatment Inspection
City of Reidsville
Reidsville WWTP - NPDES Permit No. NCO024881
Rockingham County
Dear Mr. Smith:
On February 19, 2020, Lon Snider and I of the Winston-Salem Regional Office along with
Vivien Zhong of the Central Office of Division of Water Resources (DWR) conducted an
unannounced pretreatment inspection at the City of Reidsville's WWTP located at 407 Broad
Street in Reidsville, NC. Ralph Potter, the City's pretreatment coordinator, and Ben Bani, the
operator in responsible charge for the WWTP, were present for the inspection. The purpose
of the inspection was to discuss the 1,4-dioxane fluctuations in the WWTP effluent data and
any actions that the City and Significant Industrial Users (SIUs) have taken to address 1,4-
dioxane levels.
CITY OF REIDSVILLE
The City provided a summary of 1,4-dioxane data from all SIUs since January 2018 when the
new testing method became available. The data summary confirmed that DyStar and Unifi
are two main contributors to the WWTP's 1,4-dioxane levels. It should be noted that a review
of data indicated DyStar missed sampling in October 2019, and no result was available for
that time period. The lab report stated that the lab did not bring enough bottles on the
sampling day, and thus could not collect a 1,4-dioxane sample. Additionally, the City
informed us that Unifi buys part of their raw materials from DyStar and that all industries
have been very cooperative to perform 1,4-dioxane sampling. DyStar and Unifi both
submitted corrective action plans to the City upon request. Those were also available for
review.
DYSTAR CAROLINA CHEMICAL
As part of DWR's unannounced pretreatment inspection, Mr. Snider, Ms. Zhong, Mr. Potter,
and I also visited the DyStar facility located at 209 Watlington Industrial Drive in Reidsville.
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North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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Charlie Stroman, the HSE&S Manager for this DyStar location since 2019, was available for
the visit. He explained that this DyStar facility inadvertently produces 1,4-dioxane-
containing substances as a byproduct during the manufacturing process.
Following a high 1,4-dioxane result in Reidsville WWTP's effluent in October 2019, DyStar
began sampling regularly for 1,4-dioxane. Mr. Stroman presented this data and stated that
he was creating a presentation of the data for DWR. Mr. Stroman continued to tell DWR staff
that this DyStar facility recently began a process of distilling 1,4-dioxane from the
wastewater generated during manufacturing and is collecting and storing this distillate in
totes on site. He explained this to be the reason for the decreasing 1,4-dioxane levels in
Reidsville WWTP's effluent. Furthermore, this DyStar facility shut down manufacturing over
the holidays from December 24 to December 31, 2019, which explains very low numbers of
1,4-dioxane in the Reidsville WWTP's effluent during that time period.
Dystar representatives have not yet found a way to dispose of the distillate in the totes and
continue to store it on site. DWR staff plan to revisit the site soon to inspect the totes. Mr.
Stroman did state that he has initiated research into and discussion with Starpet in Asheboro
and Shamrock Environmental in Greensboro, two companies that are installing treatment
equipment for 1,4-dioxane. Additionally, DyStar started testing raw materials and has also
requested available 1,4-dioxane data from the raw materials' manufacturers. It should also
be noted that DyStar began using Meritech Lab for 1,4-dioxane analysis starting in January
2020. DyStar is planning a meeting with DWR staff and City staff in March to further discuss
data and actions, both ongoing and planned, for all involved parties.
The Division appreciates the City's cooperation during the inspection and particularly Mr.
Potter in providing City data and accompanying us on the industry visit. We are also very
appreciative of Mr. Stroman's presentation and DyStar's interest in decreasing 1,4-dioxane
at their facility. The Division may revisit the Reidsville WWTP in the future for further
information and may also visit other Reidsville SIUs including Unifi. If you have questions or
comments regarding this letter, please contact me or Mr. Snider at (336) 776-969S and (336)
776-9700, respectively.
Sincerely,
DocuSigned by:
OD2D3CE3F1 B7456_.
Jenny Graznak
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ - WSRO
cc: DWR Laserfiche files
Charlie Stroman, III - DyStar Carolina Chemical