WQ0018087_Staff Report_20240315

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
March 15, 2024
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0018087
Attn: Erick Saunders Facility name:
Alpek Polyester USA, LLC - Cape Fear Manufacturing Facility SDU
From: Geoff Kegley
Wilmin on Regional Office
Note: This form has been adapted from the non -discharge fg acili , staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are gpplicable.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: March 13, 2024
b. Site visit conducted by: Geoff Kegley, Chad Coburn, Morella Sanchez -King
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted:
e. Driving directions:
2. Discharge Point(s): N/A
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses
II. PROPOSED FACILITIES: NEW APPLICATIONS: N/A
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Larry Young Certificate #: Backup ORC: Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: 12 acre Surface Disposal Unit (SDU). The SDU no longer receives and
activated sludge and has been closed under the approved closure plan. Post -closure care and groundwater
monitoring continues.
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
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3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ® No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program: See narrative below.
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
If no, please explain:
I t . Are the monitoring well coordinates correct in BIMS? ❑ Yes ® No ❑ N/A
If no, please complete the following ex and table if necessary):
Monitoring Well
Latitude
Longitude
No lat/long data available on wells:
MW-213, MW-2C, MW-2D, MW-
2E
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12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: see narrative below.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ® Yes or ❑ No
If yes, please explain: see narrative below
14. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
16. Possible toxic impacts to surface waters: none
17. Pretreatment Program (POTWs only): N/A
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18. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit`? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item Reason
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Based on the concentrations of constituents in excess of the standards at or
beyond the review boundary, the permittee is required per 15A NCAC 02L
.0106 (d) to demonstrate, through predictive calculations or modeling, that one
or more of the following will prevent a violation of standards at the
compliance boundary:
(A) geologic or hydrogeologic conditions;
(B) facility design; or
(C) operational controls.
Exceedances present in groundwater at
the review boundary.
If an exceedance of the standards is expected through professional judgment or
predicted through modeling at or beyond the compliance boundary, the person
may submit a plan for alteration of existing site conditions, facility design, or
operational controls that will prevent a violation at the compliance boundary
and implement that plan upon its approval by the Director.
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: )
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6. Signature of report preparer:
—DocuSigned by:
C 3/15/2024
DocuSigned by:
Signature of regional supervisor:
Date: 3/15/2024
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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This review was conducted for a request by DAK Americas to modify their surface disposal of Class B
residuals permit with an ownership name change from DAK Americas to Alpek Polyester USA, LLC.
While the name change is minor, the regional office took this opportunity to review the site history,
perform a site visit and address the ongoing groundwater exceedances. The 12-acre Surface Disposal
Unit (SDU) is no longer in operation and has been closed under the approved Closure Plan. Post -closure
care under the approved Closure Plan and groundwater monitoring under this permit continues.
The groundwater monitoring at this site has shown exceedances at the review boundary. This possibility
was anticipated before closure of the SDU and plugging of the underdrain system. Additionally, the
permittee believed some of these exceedances were attributable to the disturbances that occurred in the
area during the capping of the SDU basin and surrounding site activities. Their assumption was that
after the system was capped, there would not be further contaminant input to the groundwater system
and the trends would show a reduction in constituent levels in groundwater. Upon review of the existing
data set, the apparent trends for the constituents of interest (ammonia, nitrate, TDS, cobalt and arsenic)
have been mostly trending slightly downward or relatively stable, although still well above the standards.
MW-2E is showing a recent upward trend in ammonia. The cobalt standard in the 2016 permit was 1.0
mg/L and in the 2020 permit the standard was 0.001 mg/L. Since this change, cobalt has exhibited
exceedances, including at the sole compliance boundary well MW-2A.
Since there are persistent groundwater exceedances present at the review boundary, the permittee should
investigate per 2L .0106 (d). It is recommended that a permit condition is added to the permit for this
requirement.
The WiRO has no issues with the name change permit modification.
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