WQ0018087_More Information (Received)_20240531

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PpRster
May 28, 2024
Mr. Richard E. Rogers, Jr.
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Rogers,
Below are our comments on the proposed revision to permit WQ0018087, Alpek
Polyester — Cape Fear Manufacturing Facility SDU.
It should be noted that this SDU has a certificate of closure, and has not been in use
since 2014. Conditions 111.4, 111.5 and potential conditions 111.19 and 111.20 are not
necessary for a closed facility.
As far as condition 1.1 regarding the pollutant transport analysis, we do not believe that
this condition is warranted. It is important to note that this entire site (over 1000 acres)
is undergoing a RCRA Facility Investigation (RFI) under the direction of the NC Division
of Waste Management. Per the attached groundwater flow diagram, groundwater flow
direction across the SDU is from the north and northwest to the east. The two SDU
wells showing the most groundwater exceedances (Wells 2B and 2C) appear to be
affected by other upgradient areas including an adjacent former spray field to the west
and potentially multiple Solid Waste Management Units (SWMUs) further away. Many of
these SWMUs were closed or taken out of service prior to Alpek Polyester ownership.
Well 2A, which is located downgradient of the SDU, has the least groundwater
exceedances of any of the wells. Therefore, impacted upgradient groundwater quality
actually improves as groundwater flows under the SDU.
Because of the presence of adjacent and nearby Solid Waste Management Units that
are apparent sources of groundwater impacts upgradient of the SDU, we do not believe
that performing a pollutant transport analysis is warranted or will provide meaningful
information. Further, given the length of time that the SDU has been out of use (for a
decade), we believe that the permit should be closed and no further groundwater
monitoring should be performed for the SDU. Site -wide groundwater impacts will be
monitored and addressed under the on -going RCRA assessment and future corrective
action activities at the site.

If you would like to discuss this further, please contact me on 910-512-0296 or Scott
Spirek on 803-600-8379. Thank you.
Sincerely yours,
r
O
Matthew P Hendrickson
Cape Fear Site
Plant Manager
Alpek Polyester USA, LLC • Cedar Creek Site
3216 Cedar Creek Rd. • Fayetteville, NC 28312
910-433-8200 • www.alpekpolyester.com

GROUND WATER FLOW MAP
CAPE FEAR SDU AREA
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Nov/Dec 2018
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November and December 2018 Groundwater Potentiometric Surface
Pre -Design Investigation Report
n r o n e v n Cape Fear Site, Leland North Carolina
Alpek Polyester USA, LLC a Cedar Creek Site
3216 Cedar Creek Rd. • Fayetteville, INC 28312
910-433-8200 a www.alpekpolyester.00m
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