NC0003719_Effuent Limit_20171204

December 4, 2017
Ms. Teresa Rodriguez
Engineer
NPDES Complex Permitting Unit
North Carolina Department of Environmental Quality
Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Draft NPDES Permit Renewal
Permit NC0003719
DAK Americas Cedar Creek Site WWTP
Cumberland County
Class 2 Facility
Dear Ms. Rodriguez:
(RECEIVED/DENR/DWR
DEC 12 2017
Nater Resources
Permitting Section
DAK Americas received the draft permit to renew its NPDES permit on November 7, 2017 and a copy of
the Fact Sheet on November 8, 2017. DAK is submitting comments on two aspects of the draft permit:
1. TSS Limit at Outfall 002
2. Sample location for Total Residual Chlorine and pH.
DAK's concerns and recommended alternatives for how to address these issues are presented in
the attachment.
If you have questions or need additional information please contact Elizabeth Wike at [phone] or
[e-mail].
Sincerely,
�4
Matthew Hendrickson
Site Manager
Attachments (3)
DAK's concerns and alternatives
Table I — Calculations for TSS limits
Table 2 — Industry Effluent Guidelines, Ratio of TSS: BOD
Cedar Creek Site • 3216 Cedar Creek Rd. • Fayetteville, NC 28312
910-433-8200 (phone) 9 910-433-8366(fax)
www.dakamericas.com

DAK's Concerns and Alternatives for Draft Permit NC0003719
TSS Limit for Outfall 002
Existing Permit: 1801bs/day Draft Permit: 90 lbs. /day DAK Proposed Permit Limit 194 lbs/day
The draft permit modifies the limits for BOD and TSS at Outfall 002. NC DEQ calculated the limits using
updated flows for the DAK Americas Resins and Batch Plants (DAK) and for Clear Path Recycling (CPR).
The limits for the DAK portion of the effluent were based on effluent guideline limits whereas the limits
for the CPR portion of the effluent were based on best professional judgment. We agree with the DAK
portion of the calculation of the limits however, we question the basis for the CPR portion of the
calculation. The Fact Sheet states on page 7, "The facility indicated removal rate is 95% " This statement
was made in a conversation during a site visit conducted on June 14, 2017 but the comment pertamed to
BOD, not both BOD and TSS. The characteristics of solids in the influent and in the effluent are quite
different. The TSS in the influent consists of solids removed during bottle washing operations at CPR
(mostly adhesives and disintegrated fiber labels). These solids are degraded during the biological treatment
process. TSS in the effluent comes largely from the microorganisms in the activated sludge system used to
treat the wastewater. DAK has reviewed the EPA Effluent Guidelines for the wastewater of a wide range
of industries (sanitary, dairy, gram, pulp and paper, textiles, OCPSF, etc.). In general, the ratio of the
concentration of TSS to BOD in the effluent ranges from 1.0 for sanitary wastewater to greater than 2.0 for
wastewater from some subcategories of the pulp and paper industry. The ratio of TSS to BOD for the
OCPSF industry is 1.7. Sanitary waste water is a relatively easily treated effluent whereas the wastewater
from CPR is more complex. In the draft permit the ratio of TSS to BOD in the limits for the CPR effluent
is 0.4, a value that is much lower than those found in the Effluent Guidelines. Furthermore, DAK would
have extreme difficulty in meeting the TSS limit since the draft permit reduces the TSS limit by half DAK
requests that NC DEQ recalculate the TSS limit by using a 95% reduction factor for BOD and a TSS to
BOD ratio of 1.3 for CPR wastewater.
Table 1 compares the TSS calculations for the existing permit, the draft permit, and DAK's proposed
permit limit. Table 2 shows the ratio of TSS to BOD for various industries.
Sample Location for Total Residual Chlorine and pH
The draft permit changes the sampling location for Total Residual Chlorine and pH to the box combining
effluents of outfalls 001 and 002.
Currently Total Residual Chorine (TRC) and pH for water from the wastewater treatment plant are sampled
at Outfall 002 near the flow meter where there is easy access. There are no monitoring requirements for
Outfall 001 under the existing permit. DAK understands why NCDEQ would like to test these parameters
in the combined effluent however there are a couple of points that need to be considered. First, both TRC
and pH have very short holding times Due to the location of the combined effluents, it would be very
difficult to collect both of these samples and make it back to the laboratory within the 15 -minute holding
time. Secondly, there are safety and accessibility concerns. This is a hard location to sample. DAK
recommends that the monitoring for TRC and pH for Outfall 002 continue to be at the existing location and
that monitoring requirements for TRC and pH be added for Outfall 001.
Cedar Creek Site • 3216 Cedar Creek Rd • Fayetteville, NC 28312
910-433-8200 (phone) • 910-433-8366(fax)
www.dakamericas.com

Cedar Creek
NPDES Permit NC0003719
Effluent Limit Calculations
Table 1- Calculations for TSS Limit
PermitNC0003719
NPDES Limits
Clear Path Recycling
CPR
Resins Plant
Sanitary
Existing
Permit
Draft Permit
Proposed
Existing
Permit
Draft Permit
Proposed
143
Flow, mgd
0.111
0.250
0.250
0.127
0.127
0.005
Influent
Influent Concentration
Influent Concentration
BOD, mg/L
TSS, mg/L
850
785
1113
442
NA
NA
NA
NA
NA
NA
NA
NA
% Reduction
85%
95%
BOD 95%
Effluent
Effluent Concentration
Effluent Guidelines (Monthly Average)
BOD, mg/L
TSS, mg/l.
Ratio TSS:BOD
128
118
092
56
22
0.40
56
72
130
24
40
167
24
40
167
24
40
1.67
30
30
100
Effluent Permit Limits
BOD, lbs/day
TSS, lbs/day
118
1 109
116
46
116
151
25
42
25
42
1
1
PermitNC0003719
NPDES Limits
Combined Effluent
(CPR + Resins + Sanitary)
Existing
Draft
DAK
Permit
Permit
Proposed
158
143
143
180
90
194

Table 2 - Industry Effluent Guides
Permit NC0003719
Ratio of TSS:BOD
Ratio of TSS:BOD
BOD
TSS
concentrations
Daily Mo
Daily Mo
Daily Monthly
mg/L mg/L
mg/l. mg/L Regulatory Reference
Part 414 -Organic Chemicals, Plastics, and Synthetic Fibers
Rayon Fibers
20
17
64
24 130 40 40 CFR 414 21 Subpart B
Other Fibers
24
20
48
18 115 36 40 CFR 414 21 Subpart C
Thermoplastic Resins
20
1.7
64
24 130 40 40 CFR 414 21 Subpart D DAK Resins Plant
Thermosetting Resins
13
11
163
61 216 67 40 CFR 414 21 Subpart E
Commodity Organic Chemicals
19
15
80
30 149 46 40 CFR 414 21 Subpart F
Bulk Organic Chemicals
17
14
92
34 159 49 40 CFR 414 21 Subpart G
Specialty Organic Chemicals
15
13
120
45 183 57 40 CFR 414 21 Subpart H
Ratio of TSS:BOD
Other Industry
concentrations
Part 405 - Dairy Products Processing Point Source
Daily Monthly
Subpart
Description
Receiving Stations
15
15
A 405 12
Receiving more than 150,000 Ib/day of milk equivalent
Receiving Stations
15
15
A 405 12
Receiving less than 150,000 Ib/day of milk equivalent
Receiving Stations
13
13
A 405 15
Standards of performance for new sources
Fluid Products
16
15
8 405 22
Receiving more than 250,000 lbs/day of milk equivalent
Fluid Products
23
15
B 405 22
Receiving less than 250,000 lbs/day of milk equivalent
Fluid Products
13
13
B 405 25
Standards of performance for new sources
Cultured Products
15
15
C 405 32
Receiving more than 60,000 Ib/day of milk equivalent
Cultured Products
is
15
C 405 32
Receiving less than 60,000 Ib/day of milk equivalent
Cultured Products
13
13
C 405 35
Standards of performance for new sources
Butter
15
15
D 405 42
Processing more than 175,000 Ib/day of milk equivalent
Butter
15
15
D 405 42
Processing Less than 175,000 Ib/day of milk equivalent
Butter
1.3
13
D 405 45
Standards of performance for new sources
Cottage Cheese and Cultured Cream Cheese
15
15
D 405 52
Processing more than 25,000 Ib/day of milk equivalent
Cottage Cheese and Cultured Cream Cheese
15
15
D 405 52
Processing less than 25,000 Ib/day of milk equivalent
Natural and Processed Cheese
15
15
F 405 62
Processing more than 100,000 Ib/day of milk equivalent
Natural and Processed Cheese
is
15
F 405 62
Processing less than 100,000 Ib/day of milk equivalent
Natural and Processed Cheese
13
13
F 405 65
Standards of performance for new sources
Fluid Mix for Ice Cream and Other Frozen De55e
15
15
G 405 72
Input of more than 85,000 Ib/day of milk equivalent
Fluid Mix for Ice Cream and Other Frozen Desse
15
15
G 405 72
Input of less than 85,000 ib/day of milk equivalent
Fluid Mix for Ice Cream and Other Frozen Desse
13
13
G 405 75
Standards of performance for new sources
Ice Cream, Frozen Desserts, Novelties and Othe
15
15
H 405 82
Input of more than 85,000 ib/day of milk equivalent
Ice Cream, Frozen Desserts, Novelties and Othe
15
15
H 405 82
Input of less than 85,000 lb/day of milk equivalent
Ice Cream, Frozen Desserts, Novelties and Othe
13
13
H 405 85
Standards of performance for new sources
Condensed Milk
15
15
140592
Condensing more than 100,000 lbs/day of milk equivalent
Condensed Milk
15
20
140592
Condensing less than 100,000 lbs/day of milk equivalent
Condensed Milk
13
13
140595
Standards of performance for new sources
Dry Milk
14
15
J 405 102
Input equivalent to more than 145,000 Ib/day of milk equivalent
Dry Milk
15
15
J 405 102
Input equivalent to less than 145,000 Ib/day of milk equivalent

Dry Milk
13
Condensed Whey
15
Condensed Whey
15
Condensed Whey
13
Dry Whey
1.5
Dry Whey
15
Dry Whey
13
Part 406 - Grain Mills Point Source Category
1.5
Corn Wet Milling
16
Corn Wet Milling
27
Corn Wet Milling
13
Corn Dry Milling
09
Corn Dry Milling
05
Normal Wheat Flour Milling
13
Bulgur Wheat Flour Milling
1.0
Bulgur Wheat Flour Milling
0.7
Normal Rice Milling
05
Parboiled Rice Milling
06
Parboiled Rice Milling
04
AnimalFeed
1.0
Hot Cereal
BPT
Ready -to -Eat Cereal
10
Ready -to -Eat Cereal
0.7
Wheat Starch and Gluten
10
Wheat Starch and Gluten
10
Part 430 - The Pulp, Paper, and Paperboard Point Source Category
Dissolving Kraft
1.7
Dissolving Kraft
2.2
Dissolving Kraft
2.0
Dissolving Kraft
24
Dissolving Kraft
18
Bleached Papergrade Kraft and Soda
20
Bleached Papergrade Kraft and Soda
18
Bleached Papergrade Kraft and Soda
18
Bleached Papergrade Kraft and Soda
17
Bleached Papergrade Kraft and Soda
2.1
Bleached Papergrade Kraft and Soda
16
Bleached Papergrade Kraft and Soda
18
Bleached Papergrade Kraft and Soda
23
Bleached Papergrade Kraft and Soda
26
Bleached Papergrade Kraft and Soda
27
Bleached Papergrade Kraft and Soda
26
Unbleached Kraft Subcategory
21
Unbleached Kraft Subcategory
16
Unbleached Kraft Subcategory
21
Unbleached Kraft Subcategory
16
13
J 405.105
Standards of performance for new sources
15
K 405.112
over 300,000 Ib/day of fluid raw whey input
15
K 405 112
less than 300,000 Ib/day of fluid raw whey input
13
K 405 115
Standards of performance for new sources
1.5
L 405.122
Input equivalent to more than 57,000 Ib/day of 40 percent solids shey
1.5
L 405 122
Input equivalent to less than 57,000 Ib/day of 40 percent solids shey
1.3
L 405 125
Standards of performance for new sources
12
A 40612 (a)
20
A 40612 (b)
For plant producing modified starches of at least 15% per month
13
A 40615
Standards of performance for new sources
09
B 406 22
BPT
05
B 406 25
Standards of performance for new sources
C 406 32
No discharge of wastewater
1.0
D 406 42
BPT
0.7
D 406 45
Standards of performance for new sources
E 406 52
No discharge of wastewater
0.6
F 406 62
BPT
04
F 406 65
Standards of performance for new sources
G 406 72
No discharge of wastewater
H 406 82
No discharge of wastewater
1.0
140692
BPT
08
140695
Standards of performance for new sources
10
J 406102
BPT
10
J 406105
Standards of performance for new sources
16
A 43012 (a)
BPT
22
A 43012 (b)
BPT
2.0
A 43012 (c)
BPT
2.3
A 43012 (d)
BPT
17
A 43015
Standards of performance for new sources
20
B 430 22 (a)
Market Pulp
17
B 430 25 (a)
Market Pulp NSPS
18
B 430 22 (a)
Paperboard, coarse paper, and tissue paper
17
B 430.25(a)
Paperboard, coarse paper, and tissue paper NSPS
22
B 430 22 (a)
Pulp and fine papers
15
B 430 25(a)
Pulp and fine papers NSPS
19
B 430.22 (a)
Soda facilities where pulp and paper are produced
24
B 430 22 (b)
Market Pulp with wet debarking
26
B 430 22 (b)
Paperboard, coarse paper, and tissue paper with wet debarking
29
B 430 22 (b)
Pulp and fine papers with wet debarking
25
B 430 22 (b)
Soda facilities where pulp and paper are produced with wet debarking
21
C 430 32
Unbleached kraft facilities
16
C 430 32
Unbleached kraft -neutral sulfite semi -chemical process
21
C 430 32
BCT unbleached kraft facilities
16
C 430 32
BCT Unbleached kraft -neutral sulfite semi -chemical process

Unbleached Kraft Subcategory
Unbleached Kraft Subcategory
Part 410 - Textile Mills Point Source Category
Wool Scouring Subcategory
Wool Finishing Subcategory
Wool Finishing Subcategory
Low Water Use Processing Subcategory
Low Water Use Processing Subcategory
Woven Fabric Finishing Subcategory
Woven Fabric Finishing Subcategory
Woven Fabric Finishing Subcategory
Woven Fabric Finishing Subcategory
Knit Fabric Finishing Subcategory
Knit Fabric Finishing Subcategory
Knit Fabric Finishing Subcategory
Knit Fabric Finishing Subcategory
Carpet Finishing Subcategory
Carpet Finishing Subcategory
Stock and Yarn Finishing Subcategory
Stock and Yarn Finishing Subcategory
Nonwoven Manufacturing Subcategory
Nonwoven Manufacturing Subcategory
Felted Fabric Processing Subcategory
Felted Fabric Processing Subcategory
17
17
C 430 35
NSPS for unbleached kraft facilities where linerboard is produced
18
18
C 430.35
NSPS for unbleached kraft facilities where bag paper and other mixed products are produced
30
30
A 410 12
BPT
16
16
B 410 12
BPT
3.0
26
B 410 25
NSPS
1.0
10
C 410 32
BPT General Processing
1.0
10
C 410 35
HSPS General Processing
27
27
D 410 42
BPT
27
23
D 410 45
NSPS - Simple Manufacturing Operations
39
34
D 410 45
NSPS - Complex Manufacturing Operations
2.8
2S
D 410 45
NSPS - Desizmg
44
44
E 410 52
BPT
37
31
E 410 55
NSPS - Simple Manufacturing Operations
25
22
E 410 55
NSPS - Complex Manufacturing Operations
37
31
E 410 55
NSPS - Hosiery Products
14
14
F 410 62
BPT
19
16
F 410 65
NSPS
26
26
E 410 72
BPT
27
23
E 410 75
NSPS
1.4
14
F 410 82
BPT
19
16
F 410 85
NSPS
16
16
G 410 92
BPT
30
26
G 410 95
NSPS