NC0000892_LV-2024-0253_20240809

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7020 3160 0000 4115 0868
Return Receipt Requested
Daniel Cox, Deputy Director of Manufacturing
Arclin USA Inc
790 Corinth Rd
Moneure, NC 27559
a
���w1�p•s
NORTH CAROLINA
Environmental Quality
August 09, 2024
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(6)
and NPDES WW Permit No. NC0000892
Arclin USA, Inc
Case No. LV-2024-0253
Chatham County
Dear Permittee:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $2,831.77 ($2,700.00 civil
penalty + $131.77 enforcement costs) against Arclin USA Inc.
This assessment is based upon the following facts: a review has been conducted of the Discharge Monitoring Report
(DMR) submitted by Arclin USA Inc for the month of February 2024. This review has shown the subject facility to be in
violation of the discharge limitations and/or monitoring requirements found in NPDES WW Permit No. NC0000892. The
violations, which occurred in February 2024, are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Arclin USA Inc violated the terms, conditions or
requirements of NPDES WW Permit No. NCO000892 and G.S. 143-215. 1 (a)(6) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
Raingh Repwtal WTRe76dOGrren flrtrr Rakgh �arthGral�w2th04
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Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, I, Vanessa E.
Manuel, Assistant Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against
Arclin USA Inc:
225.00 1. of I violations of G.S. 143-215, 1 (a)(6) and Permit No. NC0000892, by discharging waste water
into the waters of the State in violation of the Permit Daily Maximum for BOD, 5-Day (20 Deg. C)
- Ouantity Daily
225.00 1 of 1 violations of G.S. 143-215, 1 (a)(6) and Permit No. NC0000892, by discharging waste water
into the waters of the State in violation of the Permit Daily Maximum for Phenol
$1,125.00 1 of 1 violations of G.S. 143-215. 1 (a)(6) and Permit No. NC0000892, by discharging waste water
into the waters of the State in violation of the Permit Monthly Average for BOD, 5-Day (20 Deg.
C) - Ouantity Daily
$ t 125.00 1 of 1 violations of G.S. 143-215.1(a)(6) and Permit No. NC0000892, by discharging waste water
into the waters of the State in violation of the Permit Monthly Average for Phenol
2 700.00 TOTAL CIVIL PENALTY
131.77 Enforcement Costs
$2,831.77 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.I(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.

Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not inchide 1vainer
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.

In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties,,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty (30) days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8.00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS §150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
6714 Mail Service Center
Raleigh, NC 27699 6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date-itime received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.

If you have any questions, please contact Cheng Zhang with the Division of Water Resources staff of the Raleigh Regional
Office at [phone] or via email at cheng.zhangfuF.Acq.nc.gov.
Sincerely,
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Laserfiche

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2024-0253 County: Chatham
Assessed Party: Arclin USA Inc
Permit No.: NC0000892 Amount Assessed: $2,831.77
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 14313-282.1(c), remission of a civil
penalty maybe granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent f tture occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare. for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent yott from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT } WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST } ADMINISTRATIVE HEARING AND
} STIPULATION OF FACTS
Arclin USA Inc )
Arclin USA, Inc )
PERMIT NO. NC0000892 ) CASE NO. LV-2024-0253
Having been assessed civil penalties totaling $2,831.77 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated August 09, 2024, the undersigned, desiring to seek remission of the civil penalty, does
hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as
alleged in the assessment document. The undersigned further understands that all evidence presented in support of
remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days
of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days
from the receipt of the notice of assessment.
This the
day of
ADDRESS
TELEPHONE
, 20
SIGNATURE

ATTACHMENT A
Arclin USA Inc
CASE NUMBER: LV-2024-0253
PERMIT: NCO000892 REGION: Raleigh
FACILITY: Arclin USA, Inc COUNTY: Chatham
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 - Effluent
Violation
Report
Unit of
Limit
Calculated % Over
Violation
Penalty
Date
Month/Yr
Parameter
Frequency
Measure
Value
Value
Limit
Type
Amount
2/22/2024
2-2024
BOD, 5-Day (20 Deg.
Weekly
Ibs/day
95.95
289.8
202.0
Daily
$225.00
C) - Quantity Daily
Maximum
Exceeded
2/29/2024
2-2024
BOD, 5-Day (20 Deg.
Weekly
Ibslday
36.10
80.18
1221
Monthly
$1,125.00
C) - Quantity Daily
Average
Exceeded
2/1/2024
2-2024
Phenol
Quarterly
Ibslday
0.02
10.304
68,593.3
Daily
$225.00
Maximum
Exceeded
2/29/2024 2-2024 Phenol
Quarterly Ibs/day 0.01
10.304 114,388.9 Monthly
Average
Exceeded
$1,125.00

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: Arclin USA Inc
Facility Name: Arclin USA, Inc
Permit Number: NCO000892
County: Chatham
Case Number: LV-2024-0253
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
No known damage to environment, public health or private property
2) The duration and gravity of the violation;
One daily maximum and one monthly average exceeded for BOD. One daily maximum and one monthly average
exceeded for phenol. All more than 100%.
3) The effect on ground or surface water quantity or quality or on air quality;
Not documented.
4) The cost of rectifying the damage;
Not documented.
5) The amount of money saved by noncompliance;
It is not believed that any money was saved by these violations. Any money saved by noncompliance is de minimis
6) Whether the violation was committed willfully or intentionally;
It is not believed that the violations were committed intentionally.
7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
There has been one CPA in the past year.
8) The cost to the State of the enforcement procedures.
$131.77
e
Date Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

Manuel, Vanessa
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
You don't often get email from [e-mail]. learn why this is important
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emalls with the Report Message
button located on your Outlook menu bar on the Home tab.
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!
Array McCoy
EHS Manager Moncure
O [phone]
A-fqo;-:..

A-ec i i n
nerr.,-,,nre Avoi -a
June 14, 2024
iris. Vanessa E. i'v4anuel - A.ssktartt 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-202.4-1_V-0316 and NOV-202.4-LV-00448
Arclin USA, L.LC
NFDCS Pennit Number NCO000892
Chatham County
Dear Ms. Manuel:
On June 6, 2024, Arclin USA, LLC (Arc'in) received both Notices of Violation and Intent to Assess C;vil
Penalty (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 BOD5 were exceeded; and in March the daily maximum and tnontltly average for
BOD5 were exceeded.
As reported to NCDEQ in March of this year, Archn's waste water treatment plant was under an upset
condition at the time samples were collected. Arclin has active.y engaged NCDEQ throughout the
recovery process. The site status and corrective action plan were presented to NCDEQ during meetmo
held on March I8'h of this year, followed up with NC'DF.Q site visit on April 10, 2024. Attached is letter
sent to NCDEQ on May 16, 2024, detailing corrective measures and observed system improvement or,-v
time, which has been substantial Below is an update ulchart provided in the letter that demonstrates the
system continues to improve
Temperature vs. Relative Phenol Conc.
• +moo e
20 0 •
v • u
+ • ¢ c
10 _♦ }
+• rr
5 I
01/29/24 02/18/24 03/09/24 03/29/24 04/18/24 05/08/24 05/29/24 06/17/24 07/07/24
4 Temperature .- Phenol Conc

[r ad"ktiun. l3OD5 urnceittr diuus ltw r also int}xo-°ed as dci;ikwnsti-,uc: in char below
DMR Effluent BOD
350.00 30000
250.00
200.00 15000 0
10000 s•
50.00
a .�c� .ya o''1o�1,yN ,�0k ,�a o`'1o�1.�e. oy1��1�yo.
1tiNTa1��
Axchn continues to niomtor tlne 5ystern c:oseIy, and is to pro_**resb oi'a-)Ilection of melais data as outlined
in the action plan to determine if any concentration of these mar be contribuiin2 to the upset conditiOn
Results of inost recent r"Ulattlr'sampling event for priority pollutant;, including phenol w.li he reported
in corresponding DMR
Archn continues to diligently monitor the sy3tem and monitor progress of corrective measures anti_
sustained normal operations are observed. We will continue to update the agency on progress.
If you lzaa-e any additional questions please conttict meat (9 [9) 545.7053
Sincerely.
�i
imC5 Gard
Plant Manager
%lay 16, 2024 letter attached

3 Locked out all the sumps such that a visua 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 26r 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 n 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 ccncentrations versus temperature The temperature rsing 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.
:s
23
'
•r•
19
`
CL
13
9
J
•Y
tnn/rQ1a
r:ieranra ir9lNtra 3r+9/Po2a
a/1a/16i4 5/a/tai.t s11v�n��
lentperlture ' p1w ICKO+.
—Ppiy tTlmplr.ttar.p
Ftyu ! - !n-houle 1'lr.;4yr)r!'rfrl5tir L "arnts & �eozp,-rRlure aver T.trve
6 We are working with a contract laboratory to determine sample col'ection requirements to
analyze For a suite of metals, as re:ommended during site visit. Unsettled and sett:ed 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-r-din-
Performamce Apphe i
May 16, 2W4
North Carolina Department of Environmental Quality
Raleigh Regional Office — Division of Water Resnurces
Attn. Donald Smith
3800 Barrett Drive
Ra eigh, NC 27609
Re: WWTP — April 10. 2024 Visit Follow Up
Arclin USA, tLC; Pernit 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 yojr Maj 8, 2024 email requesting the summary of activit.es and sampling plan
implemented in response to Oe waste water treatment plant (+n WTP) upset as discussed during April
10, 2024, site visit and initiat 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 Initial',y 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 cmntact me if you would like to disr-uss fur[her at [phone] or Sant Littlejohn at (919)
545-5742.
Ja esGard
Plant Manager
Archn
Moncure, NC

DocuSign Envelope ID: 4FE65577-84C2-4AE6-856F-424CCBAFC886
ROY COOPER
Governor
ELIZABETH S. BiSER
5ecrefory
RICHARD E. ROGERS. JR.
Director
Certified Mail # 7020 3160 0000 4115 0806
Return Receipt Reauested
James Gard, Plant Manager
Arclin USA Inc
790 Corinth Rd
Moncure, NC 27559
NORTH CAROLINA
Environmental Quality
April 11, 2024
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2024-LV-0316
Permit No. NC0000892
Arclin USA, Inc
Chatham County
Dear Permittee:
A review of the February 2024 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
001 Effluent Phenol (34694) 2/1/2024 0.015 10.304 Daily Maximum Exceeded
001 Effluent BOD, 5-Day (20 Deg. C) - 2/22/2024 95.95 289.8 Daily Maximum Exceeded
Quantity Daily (QD310)
001 Effluent BOD, 5-Day (20 Deg. C) - 2/29/2024 36.1 80.18 Monthly Average Exceeded
Quantity Daily (QD310)
001 Effluent Phenol (34694) 2/29/2024 0.009 10.304 Monthly Average Exceeded
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
D Q_A North Carok�Defiant tot Envtrwonrntal Quality i DtvtstanoFWXt Resources
Balogh Regional Otfkr . 79006arrttr Drive i Ra"KNmhCara&w27609
919.791.4200

DocuSign Envelope ID. 4FE65577-84C2-4AE6-856F-424CCBAFC8B6
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Cheng Zhang of the
Raleigh Regional Office at 919-791-4200.
Cc: Laserfiche
Sincerely,
C/DocuSignedby: n�I,, -� 11
VQ:/ILS�IJI `'. %�+1AOAALL
82918EBA832144F
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
North Caroku Depanwnto7Envirom�ental Qe thy Dhlsbnof Watef Resources
jg�D_E R4e19h Regb" ONke MW Barrett Drive Raleigh North Cxolw 37b09

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quato
Certified Mail # 7020 3160 0000 4115 1285
Return Receipt Requested
May 22, 2024
James Gard, Plant Manager
Arclin USA Inc
790 Corinth Rd.
Moncure, NC 27559
SUBJECT: RE -MAILING NOTICES OF VIOLATION & ASSESSMENT OF CIVIL PENALTY
ASSOCIATED WITH CERTIFIED RECEIPT #s: 7020 3160 0000 4115 1117
7020 3160 0000 4115 0806
Tracking Numbers: LV-2024-0102 and NOV-2024-LV-0316
NPDES Permit No. NC0000892
Arclin USA Inc
Chatham County
Dear Permittee:
Our office has not received documentation that the subject documents were successfully delivered to
you. As a result, this is another attempt to deliver these Notices of Violation to you.
�TM DEQ;
op.ro..nwu,nr,�.w�trowm� /`�
North Carolina Depacaneut of Einvironntental Quality I Diti ision of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, Noah Carolina 27609
919.791.4200

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June 4, 2024, 8:54 pm
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NPDES PERMIT NO.: NC0000892
FACILITY NAME: Arclin USA, Inc
OWNER NAME: Arclin USA Inc
GRADE: WW-2
eDMR PERIOD: 02-2024 (February 2024)
PERMIT VERSION: 5.0 PERMIT STATUS: Active
CLASS: WW-2 COUNTY: Chatham
ORC: ChristopherG. Lamm ORC CERT NUMBER: 25529
ORC HAS CHANGED: No
VERSION: 1.0 STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO
• * No Reporting Reason: ENFRUSE -No Flow-Rcuse:Recycic: ENVWTHR -No Visitation Adversc Wcathcr: NOFLOW - No Flow; HOLIDAY.- No Visitation -Holiday
Discharge Monitoring Report - Copy Of Record(COR_NC0000892_Ver_1.0_2_2024.pdf)

NPDESPERMIT ,NO.: NCO000892
FACILITY NAME: Arclin USA, Inc
OWNER NAME: Arclin USA Inc
GRADE: WW-2
eDMR PERIOD: 02.2024 (February 2024)
PERMIT VERSION: 5.0
CLASS: WW-2
ORC: Christopher G. Lamm
ORC HAS CHANGED: No
VERSION: 10
PERMIT STATUS: Active
COUNTY: Chatham
ORC CERT NUMBER: B529
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO (Continue)
"•• No ReponLng Reason: ENFRUSE No Flow-Reuse/Rccycle; ENVWTHR - No Visitation - Adverse Weather; NOFLOW - No Flow; HOLIDAY - No Visitation - Holiday
Discharge Monitoring Report - Copy Of Record (COR_NC0000892_Ver 1.0 2_2024.pdf)

NPDES PERMIT NO.: NC0000892
FACILITY NAME: Arclin USA, Inc
OWNER NAME: Arclin USA Inc
GRADE: WW-2
eDMR PERIOD: 02-2024 (February 2024)
COM PLIANCE STATUS: Non -Compliant
PERMIT VERSION: 5 0
CLASS: WW-2
ORC: Christopher G Lamm
ORC HAS CHANGED: No
VERSION: 1.0
CONTACT PHONE 11: 9195422526
PERMIT STATUS: Active
COUNTY: Chatham
ORC CERT NUMBER: 25529
STATUS: Submitted
SUBMISSION DATE:03.,28;2024
Electronically Certified by Christopher Lamm on 2024-03-28 17:58:06.915
0RCICertifier Signature:Christop her Lamm Phone 4:919-353-0762 Date
1 certify that this report is accurate and complete to the best of my knowledge.
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment.
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances. The written submission shall be made as required by part 11. E.6 of the
NPDES permit.
Electronically Signed by James Gard on 2024-03-28 18.39:33.016
Permiltee/Submilter Signature: ***James Gard Phone # : 9 1 9 5 4 5 7 0 5 3 Date
Permittee Address: 790 Corinth Rd Moncure NC 27559 Permit Expiration Date: 04.'30.2028
I certify, under penalty of law, that this document and all attachments were prepared tinder my direction or supervision in accordance with a system designed
to assure that qualified personnel property gather and evaluate the information submitted. Based on my inquiry of the person or persons who managed the
system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for
knowing violations.
CERTIFIED LABORATORIES
LAB NAME: Pace AnalyticaVArclin USA Meritech
CERTIFIED LAB it: 12/401667,5285,027
PERSON(s) COLLECTING SAMPLES: Chris Lamm Kevin Holder
PARAMETER CODES
Parameter Code assistance may be obtained by visiting hitps:.-deq.nc.gov:'about/divisions?water-resources:'edmr-user-documentation,
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow[Discharge From Site: YES indicates that No Flow"Discharge occurred and, as a result, no data is reported for any parameter on the DMR for the
entire monitoring period.
** ORC on Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittec, then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
.0506(b)(2)(D).
Discharge Monitoring Report - Copy Of Record(COR_NC0000892_Ver_1.0_2_2024.pdf)

NPDES PERNHT NO.: NC0000892
FACILITY NAME: Arclin USA. Inc
OWNER NAME: Arclin USA Inc
GRADE: W W-2
eDMR PERIOD: 02-2024 (February 2024)
Report Comments:
Phenol and BOD results under investigation
PERMIT VERSION: 5.0
CLASS: WW-2
ORC: Christopher G. Lamm
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Chatham
ORC CERT NUMBER: 25529
STATUS: Submitted

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DocuSign Envelope ID. 65151309-2226-4EB9-9AAC-4434F1AE7465
Permit NCO000892
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER AND STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Arclin USA, LLC
is hereby authorized to discharge wastewater and stormwater from a facility located at
Arclin USA, LLC
790 Corinth Road
Moncure
Chatham County
to receiving waters designated as the Haw River in the Cape Fear River Basin in accordance with
effluent limitations, monitoring; requirements, and other conditions set forth in Parts 1, 11, 111, and V
hereof.
This permit shall become effective ............................ May 1, 2023.
This permit and authorization to discharge shall expire at midnight on April 30, 2028.
Signed this day ........................................... March 25, 2023.
EVZ,
W1.Fwd by:
OJ V bW� l,A,
7287E5fiESIA40D.
Richard E. Rogers, Jr-, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 2 of 25

DocuSign Envelope ID: 65151309-2226-4EB9-9AAC4434E1AE1465
Permit NCO000892
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Put -snits issued to this fac•ility, whetherfor operation or disc•hcuge are hereby
revoked, and as of this issuance, an-y previousiv issuecl permit bearing this number is no longer•
effective. Therefore, tlrc exclusive uuthoritr to operate crud discharge from this facility arises under• the
permit conditions, requirements. terms. a►ad provisions included herein.
Arclin USA, LLC
is hereby authorized to:
Continue to operate an existing 0.100 MGD wastewater treatment facility consisting of.-
* 1.7 MG aerated equalization basin with surface aerators
0 1.6 MG active sludge aeration basin with surface aerator~
0 19.5 ft diameter clarifier
o Four (4) 20 fl x 50 ft sand filter beds
o Effluent flow meter
o Effluent composite sampler
o Three (3) 25 ft x 50 ft sludge drying beds
The facility is located at Arclin USA, LLC 790 Corinth Road, Moncure, Chatham County.
Discharge wastewater through Outfall 001 and stormwater associated with industrial
activity through Outfalls 002, 003 and 004 from said treatment works at the location
specified on the attached map into the Haw River, which are classified WS-IV waters in the
Cape Fear River Basin.
If industrial materials and activities are not exposed to precipitation or runoff as described
in 40 CFR § 122.26(g), the facility may qualify for a No Exposure Exclusion from NPDES
stormwater discharge permit requirements. Any owner or operator wishing to obtain a No
Exposure Certification must submit a No Exposure Certification NO1 form to the Division;
must receive approval by the Division; must maintain no exposure conditions unless
authorized to discharge under a valid NPDES stormwater permit; and must certify the No
Exposure Exclusion once annually.
Page 2 of 25

DocuSogn Envelope ID. 65151309-2226-4EB9-9AAC-4434F1AE7465
Permit NCO000892
Part I
SECTION A: INDUSTRIAL WASTEWATER
A. (I.) EFFLUENT LIMITATIONS AND MONIORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning upon effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge treated industrial and domestic wastewater, and reverse osmosis
reject wastewater from Ou4idl 001. Such discharges shall be limited and monitored by the Permittee
as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow
0.1 MGD
Continuous
Recording
Influent or
Effluent
BOD, 5-day, 2(Y:C
36.1 Ibs/day
95.95 lbsiday
Weekly
Composite
Effluent
Total Suspended Solids (TSS)
39.6 Ibs/day
126.85 Ibs+day
Weekly
Composite
Effluent
pH
Not more than 9.0 S.U. nor
less than 6.0 S.U.
Weekly
Grab
Effluent
NH, as N. mg/L
Weekly
Grab
Effluent
Dissolved Oxygen (DO). mg/L
Weekly
Grab
Effluent
Dissolved Oxygen (DO), mglL
Weekly
Grab
Upstream &
Downstream
Fonnaldehyde, meL
Weekly
Grab
Effluent
Temperature, °C
Weekly
Grab
Upstream &
Downstream
Conductivity, umhos/cm 2
Monthly
Grab
Effluent
Conductivity, µohms/cm
Weekly
Grab
Upstream &
Downstream
TKN, mg/L }
Weekly
Composite
Effluent
NO2-N+NO3-N, mWL
Weekly
Composite
Effluent
Fecal CoIiform. P 100 mL
Monthly
Grab
Effluent
Total Nitrogen (TN), mg/L 3
Quarterly
Composite
Effluent
Total Phosphorus (TP), mg/L
Quarterly
Composite
Effluent
Chronic Toxicity.1';
Quarterly
Composite
Effluent
Salinity, ppt -
Annually
Grab
Effluent
Total Dissolved Solids, tng/L F
Annually
Grab
Effluent
Total Arsenic, µg/L '
Annually
Grab
Effluent
Total Chlorides, mg/L 2
Annually
Grab
Effluent
Total Iron. mg/L 7
Annually
Grab
Effluent
Total PAH5
357.5 µg/L
357.5 µg L
Annually
Grab
Effluent
40 applicable PFAS compounds`
Quarterly
Grab
Effluent
Footnotes:
1. Upstream = 100 feet above the discharge. Downstream - In the I -law River prior to confluence with
the Deep River. Instream monitoring is waived as long as Permittee remains a member of the Upper
Cape Fear River Basin association. See special condition A. (4.).
2. Samples must be collected during; an RO wastewater discharge event.
Page 3 of 25

DocuSign Envelope ICY 65151309-2226-4EB9-9AAC-4434F1AE7465
Permit NCO000892
Total Nitrogen is the sum of Total Kjeldahl Nitrogen and Nitrite.: Nitrate Nitrogen, TKN and (NOS-N
NO,-N) respectively.
Chronic Toxicity (CeHodalAnia) krg 0.39%; Febiwanv, Allay, Airs.usl, and'Vowmher. See Special
Condition A. (3.).
PAH polyaromatic hydrocarbons.
Please see special condition A. (7).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 25

DocuSign Envelope ID: 65151309-2226-4EB9-9AAC4434F1AE7465
Permit NCO000892
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B ,0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the Pcrmittce
is authorized to discharge OCPSF related process wastewater as defined by 40CFR 414.91 Subpart I
from Outfall 001. Such discharges shall be limited and monitored b the Pennittee asspecified below:
Effluent
Characteristic
Daily
Maximum
Monthly
Average
Measurement
Sample
Sample
Ibs/da
lbs/day
Frequency
Type
Location'
Acenaphthene
0.034
0.013
Quarterly
Grab
E
Acenaphthylene
0.034
0.013
Quarterly
Grab
E
Acrylonitrile
0.141
0.056
Quarterly
Grab
E
Anthracene
0.034
12.95 Etg/L
Quarterly
Grab
E
Benzene
0.079
0.022
Quarterly
Grab
E
Benzo(a)anthracene
0.034
14.94 µg,'L
Quarterly
Grab
E
3,4-Benzofluoranthene
0.036
14.94 µg!L
Quarterly
Grab
E
Benzo(k)fluoranthene
0.034
0.013
Quarterly
Grab
E
Benzo(a)pyrene
0.036
1.49 µglL
Quarterly
Grab
E
Bis(2-ethylhexyl) phthalate
0.163
0.060
Quarterly
Grab
E
Carbon Tetrachloride
0.022
0.011
Quarterly
Grab
E
Chlorobenzene
0.016
0.009
Quarterly
Grab
E
Chloroethane
0.156
0.061
Quarterly
Grab
F
Chloroform
0,027
0.012
Quarterly
Grab
E
2-Chlorophenol
0.057
0.018
Quarterly
Grab
E
Chryscne
0.034
0.013
Quarterly
Grab
E
Di-n-butyl phthalate
0.033
0.016
Quarterly
Grab
E
1,2-Dichlorobenzene
0.095
0.045
Quarterly
Grab
E
1,3-Dichlorobenzene
0.026
0.019
Quarterly
Grab
E
1,4-Dichlorobenzene
0.016
0.009
Quarterly
Grab
E
1,1-Dichloroethane
0.034
0.013
Quarterly
Grab
E
1,2-Dichloroethane
0.123
0.040
Quarterly
Grab
E
I,1-Dichloroethylene
0.015
0.009
Quarterly
Grab
L
1,2-trans-Dichloroethylene
0.032
0.012
Quarterly
Grab
E
2,4-Dichlorophenol
0.065
0.023
Quarterly
Grab
E
1,2-Dichloropropane
0,134
0.089
Quarterly
Grab
E
1,3-Dichloropropylene
0.026
0.017
Quarterly
Grab
E
Diethyl phthalate
0.119
0.047
Quarterly
Grab
E
2.4-Dimethylphenol
0.021
0.011
Quarterly
Grab
E
Dimethyl phthalate
0.027
0.0 t I
Quarterly
Grab
E
,6-Dinitro-o-cresol
0.162
0.046
Quarterly
Grab
E
2,4-Dinitrophenol
0.072
0.041
Quarterly
Grab
E
2,4-Dinitrotoluene
0.166
0.066
Quarterly
Grab
E
2,6-Dinitrotoluene
0.374
0,149
Quarterly
Grab
E
Ethylbcnzene
0.063
0.019
Quarterly
Grab
E
Fluoranthene
0.040
0.015
Quarterly
Grab
E
Fluorenc
1 0.034
1 0.013
1 Quarterly
1 Grab
1 E
Page 5 of 25

DotuSign Envelope ID- 65151309-22264EB9-9AAC-4434F1AE7465
Permit N00000892
Effluent
Characteristic
Daily
Maximum
Monthly
Avera e
Measurement
Sample
Sample
lbsfda
lbs/da
Frequency
Tye
Location
Hexachlorobenzene
0.016
0.91 µg/L
Quarterly
Grab
F
Hexachlorobutadiene
0.029
0.012
Quarterly
Grab
E
Hexachloroethane
0.032
0.012
Quarterly
Grab
E
Methyl Chloride
0.111
0.050
Quarterly
Grab
F
Methylene Chloride
0.052
0.023
Quarterly
Grab
E
Naphthalene
0.034
0.013
Quarterly
Grab
E
Nitrobenzene
0.040
0.016
Quarterly
Grab
F
2-Nitrophenol
0.040
0.024
Quarterly
Grab
E
4-Nitrophenol
0.072
0.042
Quarterly
Grab
E
Phenanthrene
0.034
0.013
Quarterly
Grab
E
Phenol
0.015
0.009
Quarterly
Grab
E
Pyrene
0.039
0.015
Quarterly
Grab
E
Tetrachloroethylene
0.033
0.013
Quarterly
Grab
E
Toluene
0.047
0.015
Quarterly
Grab
E
Total Nickel
2.324
0.997
Quarterly
Grab
E
1,2,4-Trichlorobenzene
0.092
19.69 µg/L
Quarterly
Grab
E
1, 1, 1 -Trichloroethane
0.032
0.012
Quarterly
Grab
E
1.1,2-Trichloroethane
0.032
0.012
Quarterly
Grab
E
Trichloroethylene
0.032
0.012
Quarterly
Grab
E
Vinyl Chloride
1 0.156
1 0.061
1 Quarterly
Grab
E
Page 6 of 25

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