NC0000892_NOV-2024-LV-0316_20240719

Manuel, Vanessa 5effl,111141to I
From: McCoy, Amy <[e-mail]>
Sent: Friday, July 19, 2024 11:30 AM
To: Manuel, Vanessa
Cc: Pair, Amber
Subject: [External] Arclin - Letter Regarding NOV
Attachments: Envelope & Cert. Mail Receipt_6.14.24 Letter to NCDEQ.pdf; June 14, 2024 NOV
Response Letter to NCDEQ.pdf
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Good morning, Vanessa,
I am the new EHS Manager at Arclin's Moncure site, backfilling Bowman Harvey's role as of July 16'
I see that we attempted to send a response letter regarding NOV-2024-LV-0316 and NOV-2024-LV-00448 on June 14,
2024. Unfortunately, it appears this letter was returned to the our site by USPS without delivery. I've attached that letter
as a PDF for your convenience, along with the postage receipt.
Below is the address used to mail that original letter. If you could, please advise the correct mailing address.
NCDEQ—DWR
3800 Barrett Drive
Raleigh, NC 27609
Thanks!
Amy McCoy
EHS Manager - Moncure
0:[phone]
A-rciin'

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PoK.--cc Appired
June 14, 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
RE: Notices of Violation NOV-2024-LV-0316 and NOV-2024-LV-00448
Arclin USA, I.LC
NPDES Permit Number NCO000892
Chatham County
Dear l ls. Manuel
On Tune 6, 2024, Arclin USA, LLC (Arclin) received both Notices of Violation and Intent to Assess Civil
Penally (NOV) referenced above, related to exceedances reported in the Discharge Monitoring Reports
(DMR) for February and March 2024. In February, the daily maximum and monthly average effluent
limits for phenol and BOD3 were exceeded; and in March the daily maximum and monthly average for
BOD5 were exceeded.
As reported to NCDEQ in March of this year, Arclin's waste water treatment plant was under an upset
condition at the time samples were collected. Arclin has actively engaged NCDEQ throughout the
recovery process. The site status and corrective action plan were presented to NCDEQ during meeting
held on March IS"' of this year, followed up with NCDEQ site visit on April 10, 2024. Attached is letter
sent to NCDEQ on May 16, 2024, detailing corrective measures and observed system improvement over
time, which has been substantial. Below is an update of chart provided in the letter that demonstrates the
system continues to improve.
Temperature vs. Relative Phenol Conc.
25 _�_...-._..--._...
20 -0 10,
t
L
10
a
I �
5 _-„ ..... .._... s�-...... .. - _1
01/29/24 02/18/24 03/09/24 03/29/24 04/18/24 05/08/24 05/28/24 06/17/24 07/07/24
* Temperature bpi Phenol Conc

In addition, BOD5 concentrations Stave oko improved as deuionstrated in chart below.
DMR Effluent BOD
350.0(J
- —
300- 00
250.00 -
200.00
150.00..-
100.00-
50.00 - y �
t� Q
titlti°1� 0;�e-��061
Arclin continues to monitor the system closely, and is in progress of collection of metals data as outlined
in the action plan to determine if any concentration of those may be contributing to the upset condition.
Results ofinost recent regulatory sampling event for priority pollutants, including phenol will be reported
in corresponding WAR.
Arclin continues to diligently monitor the system and monitor progress of corrective measures until
sustained normal operations are observed. We will continue to update the agency on progress.
Lt you leave any additional questions please contact me at [phone]
Sincerely,
f
mes Gard
Plant Manager
May 16, 2024 letter attached.
2

3 Locked out all the sumps such that a visual assessment may be made prior to discharge and a
key is required to open valves prior to discharge to WWTP. To date, nothing unusual has been observed
in these sumps.
4 Additional measures implemented at site are detailed in letter to NCDEQon March 26, 2024.
5 We typically monitor the Equalization Basin and the Aeration Basin for pH, temperature,
dissolved oxygen concentration and level as routine process parameters. After the upset event, since
February 2024, we increased in-house process monitoring of our wastewater treatment plant to include
monitoring For variations in TSS, oxygen uptake rate, and ammonia and their impact on removal of
phenol. This has allowed us to better track relative phenol concentrations which dropped substantially.
Site plan is to continue monitoring the above parameters until our effluent phenol meets the regulatory
requirements.
For example, the chart below presents in-house sampling results for increased monitoring data from our
Equalization Basin of relative phenol concentrations versus temperature. The temperature rising to near
15 C from the lows below 7 C correlates the temperature increase to the phenol concentration
decrease.
EQ Basin
Temperature Vs Phenol Conc.
2s ,
CL
,r•
i
• 7
Ih ♦ �'P,S • Jow • Y
S3 w •� .)^� w4 A•
11 ..♦br *
9 4 ♦ o�
S , „
M a u n
1/29/101u 2118/201d 3/9/201a 3/29jMa d/l8/2024 5/8/202d 5/29/20111
w Temperature PhenolCom —Poly {Temperature.}
Figioc I - ?p4touse Plleoul rmnosurement3 u° Tetnperuture over Time
6 We are working with a contract laboratory to determine sample collection requirements to
analyze for a suite of metals, as recommended during site visit, Unsettled and settled samples are being
analyzed to better determine what metals are in solution and what metals have been taken up by the
bacteria. We will compare the metals concentration to known inhibition and toxicity values to see if
they are impacting WWTP.
We are continuing to monitor the system as described above as part of our investigation as to what
caused the upset, and work to develop any additional preventive measures based on findings.

A-rdin-
Performance Applied
May 16, 2024
North Carolina Department of Environmental Quality
Raleigh Regional Office — Division of Water Resources
Attn7 Donald Smith
3800 Barrett Drive
Raleigh, NC 27609
Re; WWTP —April 10, 2024 Visit Follow Up
Arclin USA, LLC, Permit NC0000892
790 Corinth Rd.
Moncure, North Carolina 27559
RE: Summary of Response Activities to Upset Condition
Dear Mr. Smith,
This is a follow-up to your May 8, 2024 email requesting the summary of activities and sampling plan
implemented in response to the waste water treatment plant (WWTP) upset as discussed during April
10, 2024, site visit and initial agency communication. The upset was noted upon exceedances of the
phenol and BOD parameters for sampling events conducted on February 2024 and March 2024,
respectively.
The corrective measures implemented have proved effective in gradually re-establishing normal
operating conditions. Results of weekly sampling for regulated parameters For April 2024 were in
compliance with permit limits. Note that these do not include phenol, which will be included in the May
2024 priority pollutants sampling. There has also been a considerable increase in dissolved oxygen (DO)
uptake, along with mixed liquor suspended solids (MLSS) increase which is expected to increase phenol
removal substantially.
The following is a discussion of the activities we implemented and are continuing to monitor to
understand the cause of the upset condition to prevent reoccurrence:
1 Initially walked the site looking for spills or discharges which could have reached the treatment
plant. No discharges were identified which could have increased the phenol to the concentrations
observed in the effluent.
2 Met with and interviewed plant personnel as to any unusual discharges which may have been
occurred. No discharges were identified which could have increased the phenol to the concentrations
observed in the effluent.

Feel free to contact me if you would like to discuss fUrther at [phone] or Sam Littlejohn at (919)
545-5742.
Regards,
1a es Gard
Plant Manager
Arclin
Moncure, NC