201706201013

Mr. Michael E, Johnson
Environmental Manager
DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, North Carolina 28306.7332
Dear Mr. Johnson:
Michael F. Easley, Governor
North Carolina Department of Environmillen Secretary
and Natural Resources
December 7, 2007
Subject: Relocation of Effluent Discharge
Permit No. NC0003573
Bladen County
Coleen H. Sullins, Director
sion of Water Quality
This letter is in response to your re
discharge from the DuPont facili quest for an initial determination
of relocating the discharge from o A QUAL2K model was developed b on the proposed relocation of the
Modeling and TMDL downstream of Lock y CH2M Hill to evaluate the effect
relocation Unit reviewed the &Dam 3 to upstream of the Lock and D
will not affect the dissolved OxygenQUAL2K report and concurs am• The
Permit modification request to relocate edischarge.
in the Cape Fear River, the conclusion
upont can that the
Should proceed with a
you have any questions NPDES
Rodriguez at [phone], extension 553 ermitting
requirements, please feel free to contact Teresa
Sincerely,
Gil Vinzani
East NPDES Unit Supervisor
cc: NPDES files
Fayetteville Regional Office - Surface Water Protection
Orth Carolina Division of Water Quality 1617 Mail Service Center
�ternet: h2o.enr.state.nc.us Raleigh, NC 27699-1617
512 N, Salisbury St. Phone [phone]
Raleigh, NC 27604 FAX [phone] Customer Service
1-877-623-6748

Mr. Gil Vinzani
NCDENR —Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
SUBJECT: Changes of Discharge of Toxic Substances
NPDES Permit No. NC0003573
Dear Mr. Vinzani:
DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
December 5, 2007
This letter is the written notification, as required by Part III(C)(b) of the subject NPDES
permit, of the discharge of a pollutant from the DuPont Company —Fayetteville Works, which is
not limited in the permit.
DuPont has determined that fluoromalonate is being discharged from the site's wastewater
treatment plant at a concentration exceeding the notification level of 0.50 mg/L specified in
Part III(C)(b)(1) the NPDES permit. Recent analysis of the treatment plant's clarifier effluent
showed the fluoromalonate concentration as high as 0.97 mg/L,.
The compound being discharged from the treatment plant would likely be monopotassium
fluoromalonate (CAS No. 3107-37-9) or dipotassium fluoromalonate (CAS No. 3107-37-7).
Depending on the pH, the compound in the Cape Fear River would be either fluoromalonic acid
(CAS i3o. 473-87-0), yrionopotassiuiii fluoro�z�aiuiiate or dipotassiu�n iluoruiiialo�iate.
Should you require additional information, or if you have any questions, please contact me at
[phone].
cc: Belinda Henson, NCDENR DWQ, FRO
E.I. du Pont de Nemours and Company
1;-'
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Environmental Manager

Re: Relocation -NPDES # NC0003573
Subject: Re: Relocation -NPDES # NC0003573
From: Adugna Kebede <[e-mail]>
Date: Wed, 28 Nov 2007 12:20:59 -0500
To: Teresa Rodriguez <[e-mail]>
Hi Teresa,
How are you? My concern is a more general one. The QUAL2E model was calibrated using the data from 1999.
And using the most current data for calibration will give a more realistic estimate of DO level under the
current condition. In some cases when the model is recalibrate using current data (especially when there is
major change in hydrology or hydraulics) we get different results. Therefore, it is always safe and
reasonable to list the limitations (both model limitation and data limitations) when doing the assessment.
If future modeling using a completely different (or most current) dataset gives us a completely different
set of results we should be able to revise our assessment. I hope this will help. Please let me know if you
have any further question.
Thanks.
Adugna
Teresa Rodriguez wrote:
Adugna, I am going to write a letter to DuPont regarding their request. You mentioned that you are
concerned with the use of 1999 data. What is the specific concern, I can include it in the letter for
them to address it.
Teresa
Adugna Kebede wrote:
Teresa,
I have reviewed the QUAL2E and QUAL2K modeling results from CH2M HILL. The QUAL2E model is the model
that was reviewed back in 2001 and 2002. They revised the model based on the comments given from EPA
and DWQ at the time. The technical memo includes the results from the QUAL2E model as well as the
QUAL2K model. They converted the QUAL2E model to the QUAL2K version and evaluated the relocation
scenarios. The analysis specifically addresses the effect the relocation of the DuPont plant from
downstream of Lock and Dam 3 to upstream of Lock and Dam 3 on predicted DO levels in the Cape Fear
River. The report also evaluates DuPont's nutrient data to determine whether the current loads comply
with DWQ's interim nutrient strategy for the Cape Fear River. I concur with their conclusion
concerning the impact of the relocation of the discharge on DO levels (Please refer to the January
19, 2007 Technical Memorandum entitled "Update of Cape Fear River Water Quality Model for Potential
Outfall Structure Relocation for DuPont by CH2M HILL). The only concern I have is that the QUAL2E
model was calibrated using input data from 1999. Please let me know if you want to discuss this
issue further or have any question concerning my review.
Thanks.
Adugna Kebede
f of 1 11/28/2007 5:46 PM

Relocation - NPDES # N00003573
Subject: Relocation - NPDES # NC0003573
From: Adugna Kebede <[e-mail]>
Date: Fri, 09 Nov 2007 12:11:01 -0500
To: Teresa Rodriguez <[e-mail]>
Teresa,
I have reviewed the QUAL2E and QUAL2K modeling results from CH2M HILL. The QUAL2E model is the model that
was reviewed back in 2001 and 2002. They revised the model based on the comments given from EPA and DWQ at
the time. The technical memo includes the results from the QUAL2E model as well as the QUAL2K model. They
converted the QUAL2E model to the QUAL2K version and evaluated the relocation scenarios. The analysis
specifically addresses the effect the relocation of the DuPont plant from downstream of Lock and Dam 3 to
upstream of Lock and Dam 3 on predicted DO levels in the Cape Fear River. The report also evaluates DuPont's
nutrient data to determine whether the current loads comply with DWQ's interim nutrient strategy .for the
Cape Fear River. I concur with their conclusion concerning the impact of the relocation of the discharge on
DO levels (Please refer to the January 19, 2007 Technical Memorandum entitled "Update of Cape Fear River
Water Quality Model for Potential Outfall Structure Relocation for DuPont by CH2M HILL). The only concern I
have is that the QUAL2E model was calibrated using input data from 1999. Please let me know if you want to
discuss this issue further or have any question concerning my review.
Thanks.
Adugna Kebede
� of 1 11/19/2007 10:56 AM

DuPont Qua12K
Subject: DuPont Qua12K
From: Teresa Rodriguez <[e-mail]>
Date: Fri, 02 Feb 2007 07:38:06 -0500
To: Adugna Kebede <Adugna.KebedeC�ncmail.net>
CC: Gil Vinzani <[e-mail]>
Adugna,
The Eastern NPDES Unit received a request from DuPont Fayetteville Works to evaluate a model for the
relocation of the outfall in the Cape Fear River. A copy of the model was sent to the Modeling Unit. Please
let us know if you have any comments on this model.
Thanks,
Teresa
Teresa Rodriguez, P.E.
Division of Water Quality
EAST NPDES Program
919-733-5083 ext. 553
l of 1 2/5/2007 8:04 AM

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Mr. Gil Vinzani
NCDENR —Division of Water Quality
Surface Water Protection — NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJECT: Relocation of Final Effluent Discharge
NPDES Permit No. NC0003573
Dear Mr. Vinzani and Ms. Rodriguez:
DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
January 23, 2007
Ms. Teresa Rodriguez
NCDENR —Division of Water Quality
Surface Water Protection — NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Enclosed is a copy of the final report from CH2M HILL of their modeling of the Cape
Fear River to determine what, if any, effect the relocation of the DuPont Company —
Fayetteville Works' final effluent discharge from the current position downstream of Lock
and Dam 3 to a new position upstream of the lock and dam would have on water quality.
Based on this modeling report, the relocation of the DuPont effluent discharge to
upstream of Lock and Dam 3 would have an insignificant effect on the Cape Fear River's
water quality.
As such, DuPont requests that the Division of Water Quality make a determination that
the relocation of the effluent discharge to upstream of Lock and Dam 3 would not result in any
change of this site's current NPDES permit limits.
Copies of this report have been sent to Mr. Chris Wu of the DWQ Modeling Unit and to
Ms. Belinda Henson in the Fayetteville Regional Office.
BACKGROUND
The effluent discharge from the DuPont site, which averages about 12 MGD, enters an
effluent channel that conveys the water approximately one mile to the Cape Fear River at a
point downstream of Lock and Dam 3. During the thirty-six years this site has operated, the
continuously flowing effluent has caused noticeable erosion the channel, which at times has
resulted in visible amounts of sediment discharging into the Cape Fear River.
E.I. du Pont de Nemours and Company

Mr. Gil Vinzani / Ms. Teresa Rodriguez
NCDENR — DWQ
January 23, 2007
Page 2 of 2
Before the start-up of the DuPont facility, the current effluent channel was a small natural
stormwater conveyance ditch that drained the area that is south of the DuPont manufacturing
operations. If the DuPont effluent is removed from this channel, then the channel would
revert back to its original function as a stormwater conveyance system what should have very
little if any water flow passing through it. It is believed that without the continuous flow of
the DuPont effluent, the channel would in time naturally vegetate and thereby eliminate all
future sediment discharge to the river.
PROPOSED SOLUTION
The proposed solution is to pipe the entire DuPont final effluent directly to the Cape Fear
River, which would allow the existing effluent channel to return to its original, natural state as
a stormwater ditch. To make this option cost effective, the pipe would be laid in a line that is
the shortest distance to the river, which would place the discharge of the effluent upstream of
Lock and Dam 3. Obvious benefits of this proposal are that there would be no routine
maintenance costs to DuPont, the pipeline would be less vulnerable to damage from flooding,
and the sediment to the river would be eliminated.
NPDES PERMIT CHANGE
If the proposed effluent discharge relocation should result in lower limits for this site's
NPDES permit, then the proposal would be much less attractive to DuPont, and alternative
solutions would have to be identified and evaluated.
However, the enclosed modeling demonstration indicates that the proposed effluent
relocation should not negatively impact water quality in the Cape Fear River. Therefore, it
seems appropriate that the NPDES permit limits would remain unchanged.
If you have any questions regarding this letter or if you need more details, please feel free
to call me at (910) 6784155. If you have specific questions regarding the modeling report,
please contact Ms. Ruth Swanek of CH2M HILL at 919-8754311 extension 16.
Sincerely,
E. Johnson
nental Manager
Enclosure