NC0003719_correspondence (dioxane)_20231211

dal
December 11, 2023
Dr. Sergei Chernikov
Environmental Engineer III
Industrial NPDES Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Subject: NPDES Permit No. NC0003719
Compliance Schedule for 1,4-dioxane
Dear Dr. Chernikov:
k CR)
Pp2ster
As part of renewing the NPDES permit for Alpek Polyester USA, LLC's Cedar Creek Site in Fayetteville, Cumberland
County, North Carolina, NCDEQ is implementing a 1,4-dioxane limit of 2,112.1 ltg/L in the permit. Alpek does not
currently have the capability to meet the new limit.
This limit will require a major capital investment. Alpek has developed a Rough Order of Magnitude (ROM) capital cost
estimate of approximately $10 million. Bench scale treatability studies and pilot plant work need to be performed to
evaluate the technologies. Two approaches are being considered: (1) ultra filtration, UV, and hydrogen peroxide or (2)
ultra filtration, ozone, and hydrogen peroxide. Initial discussions with vendors for treatment of 1,4-dioxane raise concern
about the ability to reduce the average level from 4,612.7 µg/L to the new pennit limit of 2,112.1 µg/L for a wastewater
treatment plant of this size. In addition, the engineering involved in this effort is extremely complex, very long lead times
are required for equipment deliveries, and there is a limited number of companies that can provide this equipment.
Alpek has developed the following compliance schedule for inclusion in the permit.
Description
Months to Complete
from the effective date
of the permit
Scheduled Completion Date
Based on an assumed effective date of the permit of
March 1, 2024
1.
Treatability study and pilot plant work
18
September 1, 2025
2
Preliminary design engineering
18
March 1, 2027
3.
NCDEQ review and environmental
Permitting
12
March 1, 2028
4.
Capital project approval full funding)
12
March 1, 2029
5.
Detailed engineering
12
March 1, 2030
6.
Equip ment bidding/procurement
18
September 1, 2031
7.
Construction
24
September 1, 2033
8.
Start-up and optimization
6
March 1, 2034
If you have questions or need additional information, please contact Elizabeth Wike at [phone] or
[e-mail].
:Sincerely,
Matthew P. Hendric son
Director. Cedar Creek Site
Alpek Polyester USA, LLC • Cedar Creek Site
3216 Cedar Creek Rd. • Fayetteville, NC 28312
910-433-8200 9 www.alpekpolyester.com