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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 v-, e (1 n 2 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 JHT/rt i' II� ��1d �' r{ ii J/9715 � l rte. r /t VIA + f �� 74 fi r'e, t'�.'. fS Gi..-.,. j,- ;fic,: l.vj' v I! l /v..C�._ vi' V u"�.(. ii c �� d ryt 6't' �' P-•--�i� S /tet r 3• ,�. �..i�f B `a c` ;,, `�< -� :i.-!'�- ! G � r ��"(� / �C `7 ' �,Z ��rv�..€' Gam-°- �s s-�'_ G•. � E' ItI-.. Cto v67, f l j �vla�,'1 �r �.— r,�f; rf�',r�� r,,,r l✓� e`j c, �_ r;,.r.. i YI r.( It c' pa IV i.0 ��.Pi�, ` v G� �t✓�1 t"r��v � (,£ ea � �?_ f �+.a'_ f`�r t', P 1� i, . f$ i ew tef r Pte' O % e �rApr t4 Z�j 78,E ac J-(", 1 ,r O5 0�r G Ll .:✓ 4�G�:'i'7 �✓'�7/ % �(. !.. t 11 9T,,, /L �^t,r-'7 K:7/yam, e` �r•;� �`,j �/ sJ c f � �. r �r ""C ,� �z•� �'P `�' In a /Jpiv ue C r sfr ' <f s R S Vie:,, a�q f i e� irk i`e S .y.ti Pr•7. IA �F' '�I cCcv-"U �'G'LF,.�a«F`�-�_ t 1✓Y'='rn c.�£� .. r �� . 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Vic;, ��,;��� r •"•_� /,� rA 04 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 a p % 4 ell J l a�l� i �q r v Y _ r