NC0003719_Fact Sheet_20230227

Fact Sheet
NPDES Permit No. NC0003719
Permit Writer/Email Contact: Sergei Chemikov, [e-mail]
Date: 02/27/2023
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑X Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Alpek Polyester USA, LLC/Cedar Creek site
Applicant Address:
3468 Cedar Creek Rd, Fayetteville, NC 28312
Facility Address:
3468 Cedar Creek Rd, Fayetteville, NC 28312
Permitted Flow:
0.5 MGD
Facility Type/Waste:
Major, 99 % industrial, 1 % domestic
Facility Class:
Class 2
Treatment Units:
Two equalization tanks, pH control pit, aeration basin, clarifier, aerobic
sludge digester (can be used as an aeration basin), sludge drying beds,
and spill basins.
Pretreatment Program (Y/N)
No
County:
Cumberland
Region
Fayetteville
Briefly describe the proposed permitting action and facility background: Alpek Polyester requested the
renewal of the NPDES permit for the Cedar Creek site. The permit expired on October 31, 2016. The
permit includes two outfalls, 001 for the effluent from the industrial WWTP and 002 for combined
cooling tower blowdown and stormwater. In 2013 DAK Americas (previous name) acquired DuPont
Teijin Film plant that operates on the site. In July 2010 Clear Path Recycling (CPR) started operating a
plastic bottle recycling facility at the site.
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The Alpek Polyester produces polyethylene terephthalate (PET) polymers. Raw materials include
terephthalic acid, ethylene glycol, and isophtalic acid. The polymerization process involves additives and
heat, then the polymer is filtered, extruded, quenched, chipped, and dried. The solid state process involves
heating to modify the polymer chain. Wastewaters from the process are subject to federal effluent
guidelines in 40 CFR 414.
The CPR plant recycles plastic bottles to produce clear and colored bottle PET flakes. The recycled
bottles are pre -washed and sorted, then cut into flakes. The flakes are washed and rinsed. The wastewater
from the process is pre-treated and then sent to the WWTP. The pre-treatment steps involve screening and
solids removal, equalization and neutralization. Wastewaters from this process are not subject to federal
effluent guidelines for Organic Chemicals, Plastics and Synthetic Fibers (OCPSF).
The WWTP receives process wastewaters, sanitary waters and utility non -contact waters. Utility waters
include non -contact waters such as demineralized water treatment effluent, boiler blowdown, cooling
water blowdown, scrubber effluent, laboratory wastewaters, and washdown from maintenance activities.
Stormwater and non -contact cooling water are discharged through Outfall 001. Outfall 001 and 002 are
combined before discharging through the same pipe to the Cape Fear River. Only stormwater conditions
were applied for outfall 001 in the last permit. Conditions for cooling tower blowdown will be added to
outfall 001.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001& 002- Cape Fear River
Stream Segment:
18-(26)b
Stream Classification:
C
Drainage Area (mi2):
4395
Summer 7Q10 (cfs)
791 (regulated)
Winter 7Q10 (cfs):
30Q2 (cfs):
4340
Average Flow (cfs):
IWC (% effluent):
0.1
303(d) listed/parameter:
No
Subject to TMDL/parameter:
No
Subbasin/HUC:
03-06-15 / 03030004
USGS Topo Quad:
H23NE
3. Effluent Data Summary
Effluent data is summarized below for the last 5 years.
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Table 1. Effluent Data Summary Outfall 002
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
MGD
0.320
0.545
0.001
0.500
BOD
lb/d
26.9
124.2
3.0
147 MA
256 DM
TSS
lb/d
54.4
134
3
189 MA
371 DM
pH
SU
7.9
8.9
7.0
6.0 — 9.0
TRC
µg/L
32
49
13
28.0
DO
mg/L
8.8
12.8
6.7
5.0
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/l of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The Middle Cape Fear Monitoring Coalition maintains two sampling station in this
segment of the river. Station B7500000 is located upstream of the discharge at 1-95 and B8290000 is
located downstream of the discharge at Lock & Dam 3.
Data was reviewed for the last 5 years. Review of the instream data for the last 5 years indicated that
instream DO standard of 5.0 mg/L was violated 1 time at the downstream station and 3 times at the
upstream station. Therefore, it is unlikely that the discharge from the facility caused downstream DO
violation.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): Yes
Name of Monitoring Coalition: Middle Cape Fear Monitoring Coalition
5. Compliance Summary
a) Summarize the compliance record with permit effluent limits (past 5 years): The facility violated
permit limits 31 times. These violations include: nine TRC violations, nine BOD violations, eight TSS
violations, three ammonia nitrogen violations, and two Benzo(A)pyrene violations.
b) Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 15 of 19 quarterly toxicity tests.
c) Summarize the results from the most recent compliance inspection: The last facility inspection was
conducted on June 15, 2022. The facility was in compliance. The inspection report states that the "facility
appeared to be properly operated and maintained".
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6. Water Quality -Based Effluent Limitations (WQBELs) Outfall 002
Dilution and Mixin Zones
ones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
The 7Q 10 flow for this segment of the river is regulated by the release of upstream impoundments. The
7Q 10 flow of 791 cfs is used for estimating dilution at the point of discharge. The IWC is 0.1 %.
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 1 SA NCAC 2B.0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
The federal effluent guidelines establish limits for BOD for this industry. (See Section 7 Technology
Based Effluent Limitations)
Ammonia
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1(summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Ammonia limits for this permit are based on a water quality model. The summer monthly average mass
limit of 13 lb/d is based on 3 mg/l. The winter monthly average mass limit of 26 mg/l is based on 6 mg/l.
Daily maximums were calculated by multiplying the monthly average by a factor of 2.
Describe any proposed changes to ammonia limits for this permit renewal: Since the limits are water
quality based, not technology based, same limits will be maintained.
Total Residual Chlorine Limitations
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/l are considered compliant with their permit limit.
Describe any proposed changes to TRC limits for this permit renewal: The TRC limit will not be
changed. The sample shall be taken after both outfalls combine before the discharge to the Cape Fear
River (same location as DO, temp and toxicity).
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
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background; 3) use of/2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 213.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between January 2012
and July 2017. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• No Limit: The following parameters will not receive a limit since they did not demonstrate
reasonable potential to exceed applicable water quality standards/criteria and the maximum
predicted concentration was <50% of the allowable concentration: arsenic, beryllium, cadmium,
cyanide, copper, chromium, lead, molybdenum, nickel, selenium, silver, antimony, fluoride,
phenols, 1,4-dioxane, and zinc.
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: The permit requires acute quarterly toxicity testing. No
changes are proposed.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/1
The application includes 6 samples for mercury. All the results were below 12 ng/L. The permit will
include annual monitoring for mercury using Method 1631 to gather data to evaluate compliance with the
TMDL.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: No TMDL is applicable for this permit.
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Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2IL 0107( c)(2) (B), 40CFR 122.47, and EPA May 2007 Memo: NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs) Outfall 002
Describe what this facility produces: polyester pellets and recycled bottle flake.
List the federal effluent limitations guideline (ELG) for this facility: § 414 Subpart D (Thermoplastic
Resins) and I (Direct discharge that use end -of -pipe biological treatment) apply to the PET production.
If the ELG is based on production or flow, document how the average production/flow value was
calculated: This ELG is based on production flow. The average process flow from the resin and batch
plant used for development of limits is 0.150 MGD.
For ELG limits, document the calculations used to develop TBEL limits: § 414.41 specifies limits for
BOD and TSS based on production flow. The wastewater from the resins plants are subject to these
limits. Average flow used for the calculations was 0.150 MGD.
§ 414.91 specifies limits for priority pollutants. (See attached OCPSF spreadsheet for proposed limits.)
If any limits are based on best professional judgement (BPJ), describe development: The wastewater
from the recycling plant is not covered by effluent guidelines. Limits for BOD and TSS were developed
based on BPJ. The flow for the CPR facility averaged 0.195 MGD. Flows from CPR have steadily
increased in the past five years. The flow projections are 0.220 MGD for 2018 and 0.250 MGD over the
next 5 years.
2011 permit: The method to calculate limits for the recycle plant was developed in 2011 based on the
treatment reduction capability of the DAK WWTP and the average BOD and TSS concentrations of the
CPR wastewater at the influent of the DAK WWTP. Average concentrations used for calculating limits
were 825 mg/1 for BOD and 785 mg/1 for TSS and a flow of 0.111 MGD. The limits were calculated
based on 85% reduction for the WWTP.
2017 permit: Since the last permit was issued based on limited data after the startup of the CPR facility
data was requested from the facility to evaluate the assumptions from 2011. DAK maintains CPR influent
data for COD and TSS but not BOD. Influent COD from the CPR facility to the DAK WWTP averaged
1,910 mg/1 for the past five years, the maximum annual average was 2,338 mg/l. TSS averaged 353 mg/1
for the past five years and the maximum annual average was 442 mg/l. Data for BOD was collected for a
period of 10 days in May and June 2017. BOD averaged 719 mg/1 during that time. A COD:BOD ratio
was calculated using the data. Applying the COD:BOD ratio to the maximum COD annual average it
results in a BOD concentration of 1,113 mg/l. The facility indicated removal rate is 95% for BOD, 85%
for TSS. The proposed limits were calculated based on influent BOD of 1,113 mg/l, TSS of 442 mg/l and
removal rate of 95% BOD and 85% TSS.
Page 6 of 9

The ratios developed for 2017 permit were used to calculate BOD/TSS limits in 2023 permit, please see
below.
Table 2. Proposed BOD and TSS limits for outfall 002
(DAK)
BPJ (CPR Recycle
Proposed
Existing
414.41
Plant)
Domestic
Permit
Limits
Limits
Flow m d
0.15
0.25
0.005
Units
m /L
lb/d
m /L
lb/d
m /L
lb/d
lb/d
lb/d
Daily
BOD
maximum
64
80
83
174
45
2
256.0
244.0
Monthly
Average
24
30
56
116
30
1
147.0
143.0
Daily
TSS
maximum
130
162
99
207
45
2
371.0
347.0
Monthly
Average
40
50
66
138
30
1
189.0
182.0
8. Effluent Limitations Outfall 001
Outfall 001 consists of cooling tower blowdown and stormwater from the production areas. The
requirements for this outfall will be modified to include typical requirements for cooling water outfalls.
The TSS daily maximum of 100 mg/l was maintained for this outfall. A monthly average limit of 30 mg/1
was added to this outfall. Monitoring for flow and oil & grease were implemented. The facility is covered
under stormwater permit NCS000389 which includes all the standard stormwater monitoring conditions.
9. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
10. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): no
If YES, confirm that antibacksliding provisions are not violated: NA
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11. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
12. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
13.Summary of Proposed Permitting Actions:
Table 3. Current Permit Conditions and Proposed Changes
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Outfall 002
Flow
MA 0.500 MGD
No change
15A NCAC 213.0505
BOD5
MA 143.0 lb/d
MA 1473.0 lb/d
TBEL & BPJ
DM 244.01b/d
DM 256.0lb/d
NH3-N
Summer:
No change
WQBEL. Based on Cape Fear
MA 13.0 lb/d
model.
DM 26.0 lb/d
Winter:
MA 26.0 lb/d
DM 52.0 lb/d
TSS
MA 182.0 lb/d
MA 189.0 lb/d
TBEL & BPJ
DM 347.0 lb/d
DM 371.0 lb/d
Fecal coliform
Monitor
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
DO
> 5.0 mg/L
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
pH
6.0 — 9.0 SU
No change
WQBEL. State WQ standard, 15A
NCAC 213.0200
Total Nitrogen
Monitor Only
No change
15A 02B .0500
Total Phosphorus
Monitor Only
No change
15A 02B .0500
Page 8 of 9

Toxicity Test
Acute limit
No change
WQBEL. No toxics in toxic
amounts. 15A NCAC 213.0200 and
15A NCAC 213.0500
Subpart I
Based on OCPSF flow
Based on OCPSF flow
TBELS are recalculated due to
Pollutants
of 0.127 MGD
of 0.150 MGD
increase in production
Mercury
Annual monitoring
No change
Statewide Mercury TMDL
1-4 Dioxane
Monthly monitoring
No change
Pollutant of concern in the Cape
Fear River
Electronic
Electronic Reporting
No change
In accordance with EPA Electronic
Reporting
Special Condition
Reporting Rule 2015.
Outfall 001
Flow
Monitor Monthly
No change
15A NCAC 2B .0505
Oil and Grease
Monitor Monthly
No change
Parameter of concern for cooling
water and stormwater discharges
TSS
DM 100.0 mg/L
No change
Parameter of concern for cooling
MA 30.0 mg/L
water and stormwater discharges
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
14. Public Notice Schedule:
Permit to Public Notice: March7, 2023
The Division will receive comments for a period of 30 days following the publication date of the public
notice. Any request for a public hearing shall be submitted to the Director within the 30 days comment
period indicating the interest of the party filing such request and the reasons why a hearing is warranted.
15. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• OCPSF Spreadsheets
16. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
• The limit and schedule of compliance for 1,4 Dioxane was added to the permit.
• The PFAS Special Condition was updated.
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