WQ0018087_Compliance Evaluation Inspection_20240313

DocuSign Envelope ID: A001 D937-34BB-4ED8-8A08-31 D5D58C551 D
Compliance Inspection Report
Permit: WQ0018087 Effective: 02/01/21 Expiration: 01/31/27 Owner: Alpek Polyester USA LLC
SOC: Effective: Expiration: Facility: Cape Fear Manufacturing Facility
County: Brunswick 3500 NE Daniels Rd
Region: Wilmington
Leland NC 28451
Contact Person: Kent W Erickson Title: Site Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0000663 Alpek Polyester USA LLC - Cape Fear Manufacturing Facility
Inspection Date: 03/13/2024 Entry Time 11:OOAM Exit Time: 12:30PM
ocugne
Primary Inspector: Geoff KegleyE�-0017E2515MB417...
DSi-� d by : Phone:
Secondary Inspector(s):
Chad Coburn
Morella Sanchez -King
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Surface Disposal of Residual Solids(503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling
Land Application Site Storage
(See attachment summary)
Page 1 of 4

DocuSign Envelope ID: A001 D937-34BB-4ED8-8A08-31 D5D58C551 D
Permit: WQ0018087 Owner - Facility: Alpek Polyester USA LLC
Inspection Date: 03/13/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
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.
Methane monitoring continues under the O&M plan in the approved closure plan. The cap showed no signs of rips or tears.
The cap has settled lower since the heavy rain events during hurricane Florence in 2018 and rainwater accumulates on top
and periodically needs to be pumped off. Some vents may have been blocked by this and some gas bubbles/bulges were
present in the cap. Alpek indicated they have already begun getting bids on the work to replace these vents and make
necessary repairs. Berms, fencing, stormwater channels/swales, and monitoring wells are all well maintained.
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. It should be noted that groundwater contamination is present at this large industrial site from past activities. The
site is also managed by the DWM's Hazardous Waste Section and cobalt is one of the constituents of interest
Page 2 of 4

DocuSign Envelope ID: A001 D937-34BB-4ED8-8A08-31 D5D58C551 D
Permit: WQ0018087 Owner - Facility: Alpek Polyester USA LLC
Inspection Date: 03/13/2024 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Distribution and Marketing
❑
Land Application
❑
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
0
❑ ❑ ❑
Are GW samples from all MWs sampled for all required parameters?
0
❑ ❑ ❑
Are there any GW quality violations?
0
❑ ❑ ❑
Is GW-59A certification form completed for facility?
0
❑ ❑ ❑
Is a copy of current permit on -site?
❑
❑ ❑
Are current metals and nutrient analysis available?
0
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
0
❑ ❑ ❑
a. TCLP analysis?
❑
❑ 0 ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑ 0 ❑
Are PAN balances being maintained?
❑
❑ 0 ❑
Are PAN balances within permit limits?
❑
❑ 0 ❑
Has land application equipment been calibrated?
❑
❑ 0 ❑
Are there pH records for alkaline stabilization?
❑
❑ 0 ❑
Are there pH records for the land application site?
❑
❑ 0 ❑
Are nutrient/crop removal practices in place?
❑
❑ 0 ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑
❑ 0 ❑
Are hauling records available?
❑
❑ 0 ❑
Are hauling records maintained and up-to-date?
❑
❑ 0 ❑
# Has permittee been free of public complaints in last 12 months?
❑
❑ 0 ❑
Has application occurred during Seasonal Restriction window?
❑
❑ 0 ❑
Comment:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? ❑ ❑ 0 ❑
Is the application site in overall good condition? 0 ❑ ❑ ❑
Is the site free of runoff/ponding? 0 ❑ ❑ ❑
Page 3 of 4

DocuSign Envelope ID: A001 D937-34BB-4ED8-8A08-31 D5D58C551 D
Permit: WQ0018087 Owner - Facility: Alpek Polyester USA LLC
Inspection Date: 03/13/2024 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
If present, is the application equipment in good operating condition?
❑
❑ 0 ❑
Are buffers being maintained?
0
❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application
❑
❑ 0 ❑
18% for subsurface application
❑
❑ 0 ❑
Are there access restrictions and/or signs?
0
❑ ❑ ❑
Is the application site free of odors or vectors?
0
❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑
❑ 0 ❑
For incorporation?
❑
❑ 0 ❑
Does permit require monitoring wells?
0
❑ ❑ ❑
Have required MWs been installed?
0
❑ ❑ ❑
Are MWs properly located w/ respect to RB and CB?
0
❑ ❑ ❑
Are MWs properly constructed (including screened interval)?
0
❑ ❑ ❑
Is the surrounding area served by public water?
❑
❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑
❑ 0 ❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑
❑ 0 ❑
Is the water table greater than 173' bls.
❑
❑ 0 ❑
Is application occurring at the time of the inspection?
❑
❑ 0 ❑
Page 4 of 4