NCS000534_Staff Report_20190710

NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000534
Clear Path Recycling
Fayetteville, NC
Facility Activities and Processes:
• SIC Code: 5162 — Plastic Materials and Basic Forms and Shapes.
• The site has 7 outfalls that discharges to the Cape Fear River, a class C stream in the Cape Fear River Basin.
• Clear Path Recycling LLC is a joint venture between Shaw Industries Group, Inc and DAK Americas LLC.
• The area now occupied by Clear Path Recycling is a Brownfields site. DuPont manufactured roundup there
in previous years. The site was left with levels of contamination that are above NC standards. The
brownfields agreement allows Clear Path and DAK to operate the site with these levels of contamination
in place while taking the protective measures listed int eh agreement.
• Clear Path Recycling is the largest PET (Polyethylene terephthalate) recycling facility in the world.
• Beginning in 2010, Clear Path Recycling planned to recycle over 280 million pounds annually of PET
Bottles (-5 billion bottles). The company was created to recycle post -consumer PET bottles to produce
Recycled PET (RPET) Flake.
• The plant recycles post -consumer PET bottles coming from municipal collection, landfill sorting, curbside
collection or deposit systems. Wash line recycling technology is used to allow highly contaminated bottles
to be recycled. The plant is designed to run 24/7. The output flake capacity will be 5,000 Kg/hr of clear
flake and 25,000 Kg/hr of green flake and will use two wash lines to achieve this output.
• In 2010, Clear Path Recycling planned to construct a recycle bottle facility inside two existing buildings.
Bottle storage will be outside on an existing impervious area. Process wastewater from the recycle bottle
operation will be treated in a new pretreatment system prior to further treatment in DAK's biological
wastewater treatment plant, permitted under NC0003719.
• Site conditions are such that DAK and Clear Path share one stormwater outfall (#001). DAK has
representative outfall status for their single #001 outfall.
• Bottles are post -consumer and may be highly contaminated. The application indicated the potential
contamination from PET bottles is minimal. However, another part of the application indicated the
recycling process can allow highly contaminated bottles.
• Approximately 75% of the RPET Flake produced by CPR is used by Shaw & DAK Americas in their
respective products as follows:
Shaw Industries: will utilize RPET flake in its polyester based carpet products.
DAK Americas: will utilize RPET flake in PET resins and Polyester Staple Fiber products
The remaining 25% of the RPET flake produced by CPR will be available for merchant sales.
• Chemicals used: NaOh, sulfuric acid, detergent (2% caustic), defoamer (ANS TH), wetting agent (Master
S4), Flocculant, PET Flake, and PET Bales.
Monitoring Information:
• The facility has been monitoring for TSS, BOD, COD, TN, TP, and pH.
• Previous permit did have a tier system.
• Elizabeth Wike requested to have BOD removed as a monitoring parameter because the holding time
required of the sample makes it hard for them to sample. BOD was originally put in the permit because of
the type of bottles present at the site. Monitoring data shows consistent BOD concentrations near of at
the benchmark. Elizabeth Wike was told that it was not likely it would be removed because BOD values
were so close to the benchmark values in Outfall B2.
• Outfall A was washed out during a hurricane. The facility is currently constructing a new outfall, and
expects to begin sampling in January 2020.
• Outfalls B3, C, D, and E were recorded as having no flow from 2010-2019.
Surface Water Information:

• This section of the Cape Fear River is listed as an impaired water experiencing problems with lead, water
temperature, fecal coliform, copper, cadmium, nickel, pH, arsenic, turbidity, dissolved oxygen, zinc, and
iron.
• There are no TMDL's for this section of the Cape Fear River.
• The 2006 303(d) includes the Cape Fear River 18-(26)c (from Grays Creek to Lock Dam 3) for a Chlorophyll
a violation. This impairment language was not added to the permit because the segment of the Cape Fer
River is not the same segment that the facility discharges into. The City of Fayetteville water supply intake
looks to be about 12 miles upstream.
Discussions with the Facility:
• Discussions began with the facility on 4/02/2019.
Regional Office Information:
• Draft to Mike Lawyer on 4/08/2019 by email.