NC0003719_Fact Sheet_20180618

Fact Sheet
NPDES Permit No. NC0003719
Permit Writer/Email Contact: Teresa Rodriguez, [e-mail]
Date:
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 2°d 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:
DAK Americas/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: DAK America 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 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.
Page 1 of 10

The DAK Americas Resin Plant 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 DAK Americas 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 period January 2012 through July 2017.
Page 2 of 10

Table 1. Effluent Data Summary Outfall 002
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
MGD
0.363
1.203
0.012
0.50
BOD
lb/d
41
620
2.3
157.6 MA
286 DM
NH3N summer
lb/d
2.3
15.1
< 0.1
13 MA
26 DM
NH3N winter
lb/d
2.4
6.2
< 0.2
26 MA
52 DM
TSS
lb/d
49
906
< 2.6
180 MA
394.5 DM
pH
SU
7.6
8.3
6.1
6-9
Temperature
°C
19.2
30
7
TRC
µg/l
27
49
< 20
28
DO
mg/l
9.1
15.6
5.4
5
TN
mg/1
2.9
7
< 1.6
TP
mg/l
0.44
1.94
0.045
Fecal Coliform
#/100 ml
31
28084
< 1
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 I-95 and B8290000 is
located downstream of the discharge at Lock & Dam 3.
Data was reviewed for the period of January 2011 to December 2016. Data is summarized in Table 2. One
sample for hardness was collected at both stations in 2016. The hardness for station B7500000 was 24
mg/1 and for station B8290000 was 16 mg/l.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): Yes
Name of Monitoring Coalition: Middle Cape Fear Monitoring Coalition
Page 3 of 10

Table 2. Instream Data Summary
B7500000
B8290000
Parameter
Average
Maximum
Minimum
Average
Maximum
Minimum
Dissolved
Oxygen
mg/1
7.8
12.2
4.6
7.6
11.8
4.6
Fecal Coliform
/100 ml
59
12000
7
57
3200
7
H
SU
7.0
8.6
6.19
6.8
8.6
5.5
Conductivity
US/cm
141
217
51
129
205
51
Temperature
deg C
1 20.6
1 32.9
1 5.2
20.4
32.3
4.8
Turbidity
NTU
13.6
97.1
28.1
14
193
1
5. Compliance Summary
a) Summarize the compliance record with permit effluent limits (past 5 years): The facility received
NOVs in February 2016 for one exceedance each for BOD and TSS daily maximum and one each BOD
and TSS monthly average.
b) Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 20 of 20 quarterly toxicity tests.
c) Summarize the results from the most recent compliance inspection: The last facility inspection was
conducted in June 20, 2016. The facility was in compliance. One aerator was out of service at the time of
the inspections.
6. Water Quality -Based Effluent Limitations (WQBELs) Outfall 002
Dilution and Mixing Zones
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 15A 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/l 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.
Page 4 of 10

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/1 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 mainteained.
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/1(acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 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 sampling location for the effluent testing was modified. 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
background; 3) use of/2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.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 or Monitoring: The following parameters will not receive a limit or monitoring, 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: cyanide, copper, total chromium, lead, nickel 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.
Page 5 of 10

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 one sample for mercury. The result was < 200 µg/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.
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
1 SA NCAC 2H. 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 1 SA 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 0.127 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 0.127 MGD.
§ 414.91 specifies limits for priority pollutants. (See attached OCPSF spreadsheet for proposed limits.)
Page 6 of 10

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/l for BOD and 785 mg/l 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/l for the past five years, the maximum annual average was 2,338 mg/l. TSS averaged 353 mg/l
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/l 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.
See attached BOD/TSS Calculations Spreadsheet.
Table 3. Proposed BOD and TSS limits for outfall 002
(DAK)
BPJ (CPR Recycle
Proposed
Existing
414.41
Plant)
Domestic
Permit
Limits
Limits
Flow m d
0.127
0.25
0.005
Units
mg/l
lb/d
mg/l
lb/d
mg/1
lb/d
lb/d
lb/d
Daily
BOD
maximum
64
68
83
174
45
2
244
286
Monthly
Average
24
25
56
116
30
1
143
157.6
Daily
TSS
maximum
130
138
99
207
45
2
347
394.5
Monthly
Average
40
42
1 66
138
30
1
182
180
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/l
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.
Page 7 of 10

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(l) 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
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.
Page 8 of 10

13.Summary of Proposed Permitting Actions:
Table 4. Current Permit Conditions and Proposed Changes
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Outfall 002
Flow
MA 0.50 MGD
No change
15A NCAC 2B .0505
BOD5
MA 157.6 lb/d
MA 143 lb/d
TBEL & BPJ
DM 286lb/d
DM 244lb/d
NH3-N
Summer:
No change
WQBEL. Based on Cape Fear
MA 13 lb/d
model.
DM 261b/d
Winter:
MA 26 lb/d
DM 521b/d
TSS
MA 1801b/d
MA 182 lb/d
TBEL & BPJ
DM 394.5 lb/d
DM 347 lb/d
Fecal coliform
Monitor
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
DO
> 5 mg/1
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
pH
6 — 9 SU
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Total Nitrogen
Monitor Only
No change
15A 02B .0500
Total Phosphorus
Monitor Only
No change
15A 02B .0500
Toxicity Test
Acute limit
No change
WQBEL. No toxics in toxic
amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
Subpart I
Annual
No change
TBELS
Pollutants
Mercury
No requirement
Annual monitoring
Statewide Mercury TMDL
1-4 Dioxane
No requirement
Annual monitoring
Pollutant of concern in the Cape
Fear River
Electronic
No requirement
Add Electronic
In accordance with EPA Electronic
Reporting
Reporting Special
Reporting Rule 2015.
Condition
Outfall 001
Flow
Monitor 1/yr
Monitor Quarterly
15A NCAC 2B .0505
Oil and Grease
No requirement
Monitor
Parameter of concern for cooling
water and stormwater discharges
TSS
DM 100 mg/l
Add a Monthly
Parameter of concern for cooling
Average of 30 mg/1
water and stormwater discharges
Total Rainfall
Monitor 1/yr
Eliminate requirement
This requirement is covered under
Event Duration
the site stormwater permit
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Page 9 of 10

14. Public Notice Schedule:
Permit to Public Notice: March 21, 2018
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):
If Yes, list changes and their basis below:
Page 10 of 10