NC0000892_NOV-2024-LV-0082_20240222

Ar-clin
Performance Applied
February 16, 2024
Ms. Vanessa E. Manuel —Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1617 Mail Service Center
Raleigh, NC 27699-1617
'RECEIVED
I F
RE: Response Letter: Notice of Violation NOV-2024-LV-0082 FEB 2 0 2024
Arclin USA, LLC.
NPDES Permit Number NC0000892 NC DEO/DWR
Chatham County Central Office
Dear Ms. Manuel:
On February 9 h, 2024, Arclin USA, LLC (Arclin) in Moncure, NC, Chatham County, North Carolina
received the above -referenced Notice of Violation (NOV) and Intent to Assess Civil Penalty issued by the
NCDEQ related to the reported November 9, 2023, Daily Maximum and November 30, 2023, Monthly
Average Priority Pollutants exceedances of phenol, 2-nitrophenol, and 4-nitrophenol discharge limits.
Arclin immediately started an investigation upon receiving the analytical results from Pace Analytical
Laboratory on December 15, 2023. The preliminary actions and data from the investigation listed below
indicate that the most probable cause may be a Pace Analytical Laboratory error. Investigative, corrective
and preventive measures are as follows:
• An operations review determined the wastewater treatment plant was operating within normal
process parameters during the sampling time period.
• There were no process upset events during the sampling time periods which could have
contributed to higher phenol discharge concentrations
• All other pollutants monitored during this sample event were in compliance with permit discharge
limits, and within normal discharge concentrations.
• A third -party wastewater treatment consultant was contracted to review the data and develop a
sampling plan to verify results and determine appropriate corrective actions if the laboratory
results found to be accurate.
• Additional samples of the wastewater treatment basins were taken on 11 /21 and 11/27 with lower
phenol concentration results that would not have exceeded discharge limits
• Arclin immediately started dosing the wastewater treatment plant with additional phenol
consuming bacteria upon receiving analytical results to reduce phenol compounds in the
wastewater treatment plant.
• Arclin will initiate a program to split samples with another analytical laboratory to try to verify
whether there is an issue with current laboratory analytical methods.
On February 9, 2024, Arclin received Ql priority pollutants test results from samples collected on
February 1, 2024, indicating an exceedance of phenol. All other compounds were non detect or below

limits. The investigation continues into each exceedance to determine the causes, corrective actions,
preventive actions moving forward.
Arclin considers all NOV's as serious environmental issues and takes immediate actions to resolve every
reported non-compliance issue. Arclin will send a follow-up letter upon completion of the investigation
into the exceedances.
If you have any additional questions please contact Bowman Harvey at [phone] or me at (919)
545-7053.
Sincerely,
ia
Gard
Manager