NC0003719_Correspondence_20230830 (2)

Baker, Caroline D
From:Chernikov, Sergei
Sent:Wednesday, June 28, 2023 10:03 AM
To:'Elizabeth M. Wike'
Cc:'James R. Perez'; 'Matthew P. Hendrickson'; 'Tony R. Freeman'
Subject:DAK Americas Cedar Creek Site NPDES Permit No. NC00037189
Attachments:DWR NPDES Strategy for 14 Dioxane 09262022_.docx; 89109-Major
Modification-2020.docx

Elizabeth,

The Division is beginning to implement a strategy for 1,4 dioxane, the copy is attached. Based on this strategy we need
to protect downstream communities that use the surface water for drinking. Based on this strategy, we have re-
evaluated your discharge with consideration of the 1,4 dioxane Water Supply Standard. The RPA indicates that we need
to implement a 1,4 dioxane limit of 2,112.1 ug/L in your permit.

We understand that it will require significant effort and funding to achieve these reductions. Therefore, the Division
typically provides a compliance schedule for a facility with a new water quality based limit. Please provide us with a
compliance schedule that is achievable for you, attached is the permit with a sample compliance schedule for your
convenience (please see page # 9).

Please let me know if you have any questions or need further discussion.

Thank you!

Sergei

Sergei Chernikov, Ph.D.
Environmental Engineer III
Industrial NPDES Permitting Unit
NEW Tel. [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617
Express Mail: 512 N. Salisbury St., Raleigh, NC 27604
NEW E-MAIL:[e-mail]

From: Elizabeth M. Wike <[e-mail]>
Sent: Tuesday, June 13, 2023 11:50 AM
To: Chernikov, Sergei <[e-mail]>
Cc: James R. Perez <[e-mail]>; Matthew P. Hendrickson
<[e-mail]>; Tony R. Freeman <[e-mail]>
Subject: RE: \[External\] DAK Americas Cedar Creek Site NPDES Permit No. NC00037189

CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.

Sergei,
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I had intended to provide comments on this permit by June 9; however, on June 7 I had an automobile accident and
have been out of commission for a couple of days. DAK’s comments are not extensive, but there are a couple of items I
would like to mention.

1. Page 2

Draft Permit
“…DAK Americas, LLC is hereby authorized to:
1. Continue to operate an existing 0.500 MGD wastewater treatment plant (WWTP) treating pre-
treated wastewaters from Clear Path Recycling and utilities and process wastewaters from the DAK
facility and consisting of:…”
DAK Comments
In late 2022 DAK sold its Specialty Polymers operation (commonly referred to as the Batch Plant and part of the
Cedar Creek site) to Selenis North America. DAK still maintains ownership of the DAK Resins and utilities
operations . The wastewater treatment plant, owned and operated by DAK, continues to treat the process
wastewater from the DAK Resins and from Selenis. The characteristics and quantity of wastewater from the
Selenis operation are the same as when it was owned and operated by DAK so there should be no impact on
how the permit limits are calculated. Also, the utilities wastewater is not pre-treated. Only the Clear Path
Recycling wastewater is pre-treated. Therefore, please consider the following language change.

DAK Americas LLC is hereby authorized to:
1. Continue to operate an existing 0.500 MGD wastewater treatment plant (WWTP) treating process
wastewaters from DAK Americas Resins, DAK utilities, and Selenis North America, and pre-treated
wastewaters from Clear Path Recycling and consisting of…

Please note that there is no comma between Americas and LLC.

2. Page 5

The Draft Permit shows the limits for vinyl chloride as 0.335 lbs/day as the daily maximum and 0.130 lbs/day as
the monthly average. By comparison, the existing permit shows the limits for vinyl chloride as 0.476 lbs/day as
the daily maximum and 0.110 lbs/day as the monthly average. It is unclear why the daily maximum value went
up and monthly average value went down.

These are the only comments that DAK has on the permit. We appreciate the work that went into developing the
permit. Thank you.

Would you please send me a copy of the Fact Sheet that was developed for this permit? Thank you.

Elizabeth

Elizabeth Wike
Sr. Environmental Engineer
DAK Americas LLC
“An Alpek Polyester® Business”
1430 Commonwealth Drive, Suite 305
Wilmington, NC 28403

Cell: [phone]
Fax: [phone]

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[e-mail]
www.alpekpolyester.com

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From: Chernikov, Sergei <[e-mail]>
Sent: Tuesday, May 9, 2023 1:13 PM
To: Elizabeth M. Wike <[e-mail]>
Subject: Re: \[External\] DAK Americas Cedar Creek Site NPDES Permit No. NC00037189

Elizabeth,

Sorry, we had a glitch in our notice system and permits were noticed on time. Please provide your comments by June 9.

Thank you!

Sergei

Get Outlook for iOS

From: Elizabeth M. Wike <[e-mail]>
Sent: Tuesday, May 9, 2023 11:13:32 AM
To: Chernikov, Sergei <[e-mail]>
Subject: \[External\] DAK Americas Cedar Creek Site NPDES Permit No. NC00037189

CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.

Sergei,

DAK Americas received the draft NPDES permit today, May 9, 2023. The letter, dated March 21, 2023, states that DAK
has until April 24, 2023 to comment; however, the letter and permit were not mailed until May 3, 2023.

DAK requests 30 days to review the permit and provide comments. Please call me to discuss. Thank you.

Elizabeth Wike
Sr. Environmental Engineer
DAK Americas LLC
“An Alpek Polyester® Business”
1430 Commonwealth Drive, Suite 305
Wilmington, NC 28403

Office: [phone]
Cell: [phone]
Fax: [phone]

[e-mail]
www.alpekpolyester.com

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