HomeMy WebLinkAbout201706201037DuPont -Fayetteville Works: Addition of DMSO wastestream to on-site WWTP
Subject: DuPont -Fayetteville Works: Addition of DMSO wastestream to on-site WWTP
Date: Wed, 17 Jut 2002 16:20:36 -0400
From: "Michael E Johnson" <Michael. E.JohnsonC�USA.dupont.com>
To: Mike.TempletonC�ncmaiLnet
Mike,
I heard your telephone message from this morning. Attached is a note I
sent to Charles Weaver on the same subject.
Let me know if this provides you all the needed information that you
requested.
Thanks for your help and guidance.
Mike
---------------------- Forwarded by Michael EJohnson/CL/DuPont on
07/17/2002 04:14 PM ---------------------------
Michael E Johnson
07/16/2002 03:50 PM
To: Charles.WeaverC�ncmail.net
cc: (bcc: Michael EJohnson/CLlDuPont)
Subject: DuPont -Fayetteville Works: Addition of DMSO wastestream to
on-site WWTP
Charles,
The DuPont -Fayetteville Works would like to begin introducing a new waste
stream to the influent to the on-site wastewater treatment plant (WWTP).
What, if anything, must DuPont do before it can begin treating the new
waste stream in the WWTP? As you wilt read below, there should be no
reason to modify the existing NPDES permit (No. NC0003573) as a result of
this minor change.
The waste stream is currently being sent off-site to a DuPont facility in
New Jersey where it is treated in that site's WWTP.
The new waste stream is the Waste DMSO" from the Nafion(R) manufacturing
process.
* DMSO = dimethyl sulfoxide CH3 - SO - CN3 [CAS No. 67-68-5]
The existing Waste DMSO Storage Tank will continue to be used to store the
Waste DMSO and will act as a very large holdup tank. The waste stream is
generated batchwise, with sometimes a couple months between the generation
of the next batch. The storage tank will allow this waste stream to be
added slowly and consistently to the WWTP at an anticipated rate to five
(5) gallons per hour.
The composition of the waste stream is as follows:
Demin Water 64%
Potassium hydroxide 25%
Dimethyl sulfoxide 8%
Potassium fluoride 3%
of 2 7/30/2002 10:09 AM
DuPont -Fayetteville Works: Addition of DMSO wastestream to on-site WWTP
Methanol Trace
Phenols Trace
At the five gallon per hour rate, there would be approximately 80 lb/day of
DMSO entering the WWTP. At our usual influent flow rate of 1 MGD, the
concentration of DMSO in the influent would be 9.6 mg/Las DMSO. We
anticipate that after a brief acclimation period for our bacteria, that the
majority of the DMSO will be biologically degraded in the WWTP.
The potassium hydroxide {KOH) is fisted as a hazardous substance with a
reportable quantity of 1,000 pounds p'er day. There wilt be 250 pounds per
day as KOH leaving the Nafion(R) process. However, it will neutralized
either prior to introduction into the WWTP, or it will be neutralized
within WWTP, with the result of the KOH being converted to potassium
sulfate and water. Potassium sulfate is not a'regulated substance.
DMSO isnot a regulated chemical in the federal regulations.
Potassium fluoride is not a regulated chemical in the federal regulations.
The natural commingling of the subject waste stream with other wastewaters
in the WWTP will result in the methanol and phenol being at non-detectable
levels if they were to pass unaltered through the WWTP.
I would appreciate it if you or another member of the NPDES Permitting
Section would let me know relatively quickly as to what is needed to begin
treating this new waste stream.
If you need more information, please feel free to call me at 910-678-1155.
Thank you for your help.
Michael E. Johnson
Environmental Manager
DuPont Company
Fayetteville Works
2 of 2
7/30/2002 10:09 AM
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This will be a common result of requiring nitrogen removal for these small
systems, if it can ever be accomplished at existing facilities with limited space.
Any previous planning or task force discussions that I have been a party to
regarding nitrogen removal for smell systems involved possible limits of 12 mg/1 as
in the Beachwood permit alternatives analysis requirement. Limits of 12 mg/1 would
require removal facilities on most small plants whereas 6 mg/1 would require removal
on all plants.
The existing rule. allocates 280,000 pounds of n7trogen to small dischargers
with a total of 2,800,000 pounds for all dischargers.
The proposed new rule allocates only 138,000 pounds to small dischargers with
a total of 3,000,000 pounds for all dischargers. Therefore, the total nitrogen
allocated increased by 200,000 pounds (7X) and small discharges allocation decreased
by 142,000 pounds (51X).
If the 138,000 pounds allocated to small systems equates to 6 mg/1, then the
existing rule allocation of 280,000 pounds equates to slightly -Quer 12 mg/1.
• �:..
It is significantly more economically reasonable-to.remove nitrogen on a large
scale where municipalities have treatment plants on 7ar.ge traria of land in remote
locations, .These �faciaaties serve large customer. bases and can,:�easily spread the
cost of nitrogen_remoyal facilities over the customer:base without •a significant
impact on the monthly bills. In addition, the large facilities can -afford to have
employees present at the plant 24 hours per day to deal with potential. methanol or
other problems. It is not economically feasible to install nitrogen removal on small
facilities or to provide 24 hour per day operation.
Nitrogen removal should not be required on these small facilities.
Heater and the Carolinas Chapter request the allocation to small dischargers
be changed to 345,000 pounds, which equates to approximately 15 mg/1 as a
concentration.
Your favorable consideration will be greatly appreciated. If I can provide
clarification of any of these comments, please do not hesitate to contact me at 919-
467-8712, Ext. 37 or a -mail jtweed@huinc.com.
Sincerely,
�d���
Je y H. Tweed
V ce President
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DuPont hluoroproducts
Mr. David Goodrich
NCDENR — Division of Water Quality
Water Quality Section — NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJECT: Changes in Discharges of Toxic Substances
NPDES Permit No. NC0003573
Dear Mr. Goodrich:
DuPont F-luoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
Apri123, 2002
This letter requests that your office clarify a requirement found in Part III of the
subject North Carolina issued NPDES permit.
The DuPont Company — Fayetteville Works facility manufactures many fluorocarbon
compounds. Each of these processes creates a wastewater that is ultimately treated in and
discharged from the on-site wastewater treatment plant (WWTP).
As with all chemical processes, side reactions to the desired product reaction create
dozens or hundreds of byproducts in very low concentrations. The fluorochemistry
involved in this processes is exceptionally complicated, and most of the byproducts are
unknown compounds. There is no standard method to identify these compounds, so a
research methodology utilizing nuclear magnetic resonance (NMR) spectroscopy must be
employed by an on-site DuPont chemist to qualify and quantify an unknown fluorocarbon
compound.
DuPont is considering a research effort
to identify and quantify some of the unknown
fluorocarbon byproducts in the various processes at the Fayetteville Works facility.
Samples would be taken from the wastewater discharge nearest to the process so as to
maximize the possibility of a detectable concentration.
In Part III(C) of the subject NPDES permit, there is a requirement for the permittee to
notify the Division of Water Quality "as soon as it knows or has reason to believe... that
an activity has occurred or will occur which would result in the discharge, on a routine or
frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge
All exceed... one hundred micrograms per liter (100 pg/L)".
The question to the Division is whether or not the subject permit requires, pursuant
to Part
III(C), reporting of compounds that are detectable only in the discharge of the
manufacturing process, and that would not be detectable exiting the site's WWTP?
E. I. du Pont de Nemours and Company � Printed on Recycled Paper
FL -4 Rev. 6/99
Or. David Goodrich
NCDENR — DWQ
Apri123, 2002
Page 2 of 2
For example, assume a wastewater sample is taken from the discharge of a
manufacturing process and using NMR spectroscopy, Compound A is detected at a
concentration of 20 mg/L. The NMR detection limit for Compound A is determined to be
1 mg/L, meaning any concentration less than 1 mg/L cannot be detected nor quantified.
Assume that the process wastewater stream is added to the many other wastewater
streams sent to the WWTP and that it represents 1% of the total WWTP influent. This
stream would be diluted 100 times with the other wastewaters, so that the concentration
of Compound A entering the WWTP is now 0.2 mg/L (200 µg/L) and cannot be detected
using the NMR spectroscopy method.
In the above example, Compound A is entering the WWTP at a calculated
concentration of 200 µg/L. There is no literature available to indicate if Compound A is
degraded in an activated sludge biological treatment system. If one assumes that little of
the material is biodegraded, then it follows that there is as much as 200 µg/L of
Compound A exiting the WWTP through the permitted Outfall 001. Per the requirement
of Part III(C), if the discharge exceeds the 100 µg/L "notification level", then the Division
of Water Quality would have to be notified. However, analysis of Outfall 001 shows no
detectable concentration of Compound A because the calculated concentration of
0.2 mg/L is less than the detection limit (1 mg/L) of the only known analytical method for
detecting Compound A.
In the above example, would a permitee be deemed to know or have reason to
believe that a toxic substance is being discharged above the "notification level" and
therefore be required to notify the Division of Water Quality of the discharge of
Compound A pursuant to Part III(C) of its NPDES permit?
If you have any questions regarding this inquiry, or if you need more details, please
feel free to call me at (910) 678-1155.
Michael E. Johnson
Environmental Manager
cc: Mr. Paul Rawls, NCDENR Division of Water Quality, Fayetteville
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