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HomeMy WebLinkAbout201706201102DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0003573 Facility Information Applicant/Facility Name: I E.I. DuPont de Nemours & Co — DuPont Fayetteville Works Applicant Address: 22828 NC Hwy 87W, Fayetteville, NC 28306-7332 Facility Address: 22828 NC Hwy 87W, Fayetteville, NC 28306-7332 Permitted Flow (MGD): 2 MGD — WWTP (001) Type of Waste: Industrial Facility Classification: III Permit Status: Renewal County: Bladen Miscellaneous Receiving Stream: Cape Fear River Regional Office: Fayetteville Stream Classification: C USGS Quad: Duart 303(d) Listed? No Permit Writer: Teresa Rodriguez Basin/Subbasin: 03-06-16 Date: 12/6/06 Drainage Area (mi2): 4790 Summer 7Q10 (cfs) 791 — Winter 7Q10 (cfs): 30Q2 (cfs) Average Flow (cfs): 5676 Lat. 340 50'25" N Long. 781)50'09"W IWC (%): 17% Summary: E.I. DuPont de Nemours & Co submitted a permit renewal application on May 2, 2006 for the renewal of its NPDES permit. The DuPont Fayetteville Works manufacturing facility includes the Butacite® plant, the Nafion® plant, the Teflon® plant, and the APFO plant. A new process will be added in 2007 to produce Polyvinyl Fluoride (PVF) resins. The process wastewaters generated from the new facility will be treated in the existing treatment plant. DuPont has requested to modify the permit to include the new process wastewaters generated by the PVF manufacturing and to eliminate outfall 006 from the permit. anufacturing Facilities: M Buticite® Manufacturinq • DuPontTm Buticite® Interlayer plastic sheeting — This is the final product used in safety glass such as automobile windshields. Butacite® is manufactured in large rolls, shipped out in refrigerated trucks to glass manufacturers. The refrigeration is a requirement as butacite sticks to itself at temperatures above 60°F. • Polyvinyl butyral (PVB) resin -the resin is shipped to other DuPont facilities for final processing. Wastewaters generated at this facility are treated in the on-site wastewater treatment plant. Nafion® Manufacturing Five products are manufactured at the Nafion® manufacturing facility: • DuPontTM Nafion® membrane — a plastic film used in electrochemical fuel cells; • Nafion® resins — ultimately extruded into a finished film; • Nafion® solution — generated during the production of resin; Fact Sheet NPDES NC0003573 Page 1 the chloroalkali industry and in • FLPR vinyl ether monomers — shipped to other DuPont locations to produce various fluorochemical products such as DuPontTM Teflon®. • HFPO monomers — shipped to other DuPont locations to produce various fluorochemical products such as DuPontTM Teflon®. Wastewaters generated at this facility are neutralized and treated in the on-site WWTP. Teflon® Manufacturing DuPontTM Teflon® FEP resin — this resin is used in the electronics industry as a coating for wire, as well as many other uses. Wastewaters generated at this facility are treated in the on-site wastewater treatment plant. Ammonium Perfluorooctanoate (APFO) Manufacturing APFO is used to produce fluoropolymers and fluorinated telomers that are shipped to other DuPont facilities. Wastewaters generated in this process are collected and shipped off-site for disposal. Sentry Glass Plus® Manufacturing DuPontTM Sentry Glass Plus® - this is an ionoplast interlayer laminate used for laminated safety glass in side, rear, and overhead automobile windows. It is also used in architectural applications desiring safety glass. This manufacturing process started in June 2005. No process wastewaters are generated from this process. Non -contact cooling water is discharged to Outfall 002. Proposed PVF Manufacturing This facility will produce Polivinyl fluoride resins (PVF) and is expected to start production in October 2007. PVF is used in DuPontTM Tedlar® fluoropolymer film manufactured at other DuPont facilities. Tedlar® is used in the photovoltaic industry in photovoltaic cells and the aircraft industry for interior cabin surfaces, as well as other uses. The wastewater generated at this site will be treated at the on-site wastewater treatment plant. Wastewater from the PVF process will contain unreacted vinyl fluoride, with little or no BOD value. The expected concentration of vinyl fluoride at outfall 0002 is 0.0035 mg/I. Non -contact cooling water, condensate and stormwater will be discharged to Outfall 002. Wastewater Treatment: Process wastewaters and stormwater from process areas are collected in sumps in the respective manufacturing areas and conveyed via gravity sewers to the wastewater treatment plant. Sanitary sewage is conveyed separately to the WWTP. The treatment system consists of the following: • Influent pump sump • 850,000 gallon Equalization basin with two floating submerged mixers • 250,000 aerated predigester tank • 1,700,000 gallon aeration tank with a bottom diffused air system with supplemental floating mixer that injects air through submerged rotors • Two clarifiers • 175,000 gallon emergency retention tank • Dissolved Air Flotation Unit for sludge treatment • 47,000 gallon sludge storage tank • Rotary filter for thickening • Sludge press and steam heated dryer The treatment system discharges through Outfall 001 to the main discharge channel. Non -process cooling waters and stormwater are conveyed to ditches and discharged to the main discharge channel. The combined flows are discharged through Outfall 002 to the Cape Fear River below Lock and Dam #3. Fact Sheet NPDES NC0003573 Page 2 Effluent Guidelines. DuPont's Fayetteville Works is regulated under the Organic Chemicals, Plastics and Synthetic Fibers Category, 40 CFR 414 Subpart D. These guidelines apply to products manufactured under SIC codes 2869 and 2821. SIC code 2869 includes Nafion® solution, Vinyl Ether and HFPO monomers manufacturing. SIC code 2821 includes Teflon® resin, polyvinyl fluoride resin, polyvinyl butyral resin and Nafion® resin manufacturing. Manufacturing of Nafion membrane, Butacite® sheeting and Sentry Glass plus are classified as SIC code 3081 which is not regulated by the OCPSF guidelines. Regulated process flow for Outfall 001 is approximately 1,085,660 gpd. This flow includes the flow from PVF manufacturing process, which is set to start up in 2007. Average flow for the past 3 years was 0.832 MGD. EG limits - Subpart D -Thermoplastic Resins. 414.41 rivicess iww - i.uaoen wiuu. The calculated limits are higher than current limits in the permit. The existing limits will remain in the permit. Compliance Summary: Outfall 001 Process Wastewater Treatment Plant Data reviewed: 1 //1 /2004 - 9/30/2006 riow t3UU :TSS - O&G Temp MGD 1b/d Ib/d - ` mg/I C Average 0.0832 63.9 132.8 5.95 27 Maximum 1.275 2981 349.3 28. 30 Minimum 0.078 < 2.6 8.7 < 5 9 40 CFR 414 Subpart (Parameters -Monitoring was waved based on a demonstration made by the Permittee in accordance to 40 CFR 122.44(a)(2)(i). The permit application includes a pollutanf analysis -for these parameters. No parameters were detected. Notices of Violation -The facility received two NOVs: March 2005 for BOD monthly average and daily max and March 2006 for BOD daily max. Outfall 002 Combined cooling waters, stormwater and process WWTP effluent Data reviewed: 1//1/2004 - 9/30/2006 Avera e Maximum Minimum Flow Effluent Limitations Effluent Limitations Domestic WW Proposed limits MGD 12.61 concentration Mass limits (mass limits) mass limits`' Parameter Maximum MaximumDaily Monthly 5030 Monthly Daily Monthly Daily Monthly 19 Daily Average Maximum Average Maximum Average Maximum Average {mg/I) (Ib/day) (Ib/day) (Ib/day) (Ib/day) (Ib/day) (Ib/day) mg/1 BOD 64 24 579.5 217.3 3 2 582.5 219.3 TSS 130 40 1177.1 362.2 3 2 1 1180.1 364.2 rivicess iww - i.uaoen wiuu. The calculated limits are higher than current limits in the permit. The existing limits will remain in the permit. Compliance Summary: Outfall 001 Process Wastewater Treatment Plant Data reviewed: 1 //1 /2004 - 9/30/2006 riow t3UU :TSS - O&G Temp MGD 1b/d Ib/d - ` mg/I C Average 0.0832 63.9 132.8 5.95 27 Maximum 1.275 2981 349.3 28. 30 Minimum 0.078 < 2.6 8.7 < 5 9 40 CFR 414 Subpart (Parameters -Monitoring was waved based on a demonstration made by the Permittee in accordance to 40 CFR 122.44(a)(2)(i). The permit application includes a pollutanf analysis -for these parameters. No parameters were detected. Notices of Violation -The facility received two NOVs: March 2005 for BOD monthly average and daily max and March 2006 for BOD daily max. Outfall 002 Combined cooling waters, stormwater and process WWTP effluent Data reviewed: 1//1/2004 - 9/30/2006 Avera e Maximum Minimum Flow BOD COD Fluoride TP TN MGD 12.61 mg/I 57.5 mg/I 52.0 Ib/day 834 mg/I 16.2 mg/I 2.7 22.24 212 102.0 5030 302.0 26.5 2.96 <2 <25 19 <0.1 0.5 Whole Effluent Toxicity -The permit requires a quarterly chronic test at 3.3 %. The facility passed all the tests for the period of Feb 2002 to Aug 2006. Notices of Violation -There were no NOVs for this outfall. Priority Pollutant Analysis - No parameters were detected in the PPA above the allowable concentrations. Fact Sheet NPDES NC0003573 Page 3 Instream data review: There are monitoring stations in the Cape Fear River upstream (138301000) and downstream (138302000) of the discharge. Data from the monitoring stations don't show water quality concerns. 68301000 - U stream station at Lock & Dam #3 m a ECO ro L� z z O LL o Z NO ~ 0 U U) F- z Mg/1 , SU pmhos/cm /100 ml mg/1 NTU mg/1 mg/1 mg/1 mg/1 A v6 Ma�irr>urt� 8.3 6.9 154.2 43.9 21.1 15.2 0.1 0.7 0.7 0.2 Minirrram 12.8 7.7 261.0 3000.0 124.0 33.0 0.5 1.2 1.4 0.3 1\4 IN Av e 5.7 5.9 81.0 6.0 3.9 4.5 0.0 0.1 0.4 0.1 138302000 -Downstream station near Tolarsville SUMMARY OF PROPOSED CHANGES: • Outfall 006 was eliminated from the permit. This outfall authorized the discharge of wastewaters from the Nafion® manufacturing process but current procedure is to send the wastewater to the WWTP for treatment. DuPont requested to eliminate the outfall from the permit as they will continue to send the wastewater to the WWTP. • The Supplement to Cover Sheet includes authorization to discharge treated wastewater from the PVF process. The process will start up in late 2007. Fact Sheet NPDES NC0003573 Page 4 Draft Permit to Public Notice: December 20, 2006 ..Permit Scheduled to Issue: � February 12, 2007 NPDES DIVISION CONTACT If you have questions regarding any of the above information or on the attached permit, please contact Teresa Rodriguez at (919) 733-5083 ext. 553. NAME: �� DATE: �� REGIONAL OFFICE COMMENTS NAME: SUPERVISOR TE: � � ' .� ij ' ��. TE: I—�'—� 7 Fact Sheet t�rnnFc �.Trnnnzc�2 a :. jM v_._t� � JAN � �� 2Gel� g � FACILITY DuPont -Fayetteville OCPSF Flow 1.08566 MGD Outfall 001: How Is based on processes only 7010s 791 cis Qavg 5676 cis Permitted Flow 2 MGD Human Hlth Human Hlth Allowable Allowable Limit Limit Federal or Standard Standard Allowable Allowable Aquatic Life Human Hlth Limit Daily Monthly Daily Monthly Daily Monthly State Aquatic Organisms cone. Aquatic cone Organisms Based Max Avg. max avg max avg Life Life Organisms on: Parameter ug/I ug/I #/d #/d stdrd pg/I jug/] Ng/I Acyl #/day #/day #/day Acenaphthene 59 22 0.534 0.199 Federal no stdrd 990.00 no sidrd 253599.68 no stdrd 4226 661 OCPSF 0,534 Ii/clay 0,199 Acenaphthylene 59 22 0.534 0.199 Federal no stdrd no sidrd no stdrd no sidrd no stdrd no stdrd OCPSF 0,534 #/day 0 199 Acrylonitrile (c) 242 96 2.191 0.869 Federal no sidrd 0.25 no stdrd 457.99 no stdrd 7.633 OCPSF 2,191 #/day 0,869 Anthracene 59 22 0.534 0.199 Federal no stdrd 40000.00 no stdrd 10246451.61 nostdrd 170774194 OCPSF 0,534 #/day 0.199 Benzene (c) _ 136 37 1.231 0.335 State no stdrd -' `71.40 no stdrd 130802.50 no stdrd 2180.042 OCPSF 1,231 #/day 0,335 Benzo(a)anthracene (c, P, 59 22 0.534 0.199 Federal no stdrd 0.018 no stdrd 32.98 no stdrd 0.550 OCPSF 0,534 #/day 0,199 3,4-Benzofluoranthene(c, 61 23 0.552 0.208 Federal no stdrd 0.0311 no stdrd 56.97 no stdrd 0.950 OCPSF 0.552 #/day 0,208 Benzo(k)fluoramhene (c,P 59 22 0.534 0.199 Federal no sidrd 0.0180 no stdrd 32.98 no stdrd 0.550 OCPSF 0.534 #/day 0 199 Benzo(a)pyrene (c, PAH) 61 23 0.552 0.206 Federal no stdrd 0.0311 no stdrd 56.97 no sidrd 0.950 OCPSF 0,552 #/day 0,208 Bis(2-ethylhexyl) phthalatE 279 103 2.526 0.933 Federal no stdrd 2.20 no stdrd 4030.33 no stdrd 67.172 OCPSF 2,526 #/day 0,933 Carbon Tetrachloride (c) 38 18 0.344 0.163 State no stdrd 4.42:x: - no stdrd 8097.30 no stdrd 134,955 OCPSF 0,344 #/day 0,163 Chlorobenzene 28 15 0.254 0.136 Federal no stdrd 21000.00 no stdrd 5379387.10 no stdrd 89656 452 OCPSF 0.254 #/day 0.136 Chloroethane 268 104 2.427 0.942 Federal no stdrd no sidrd no sidrd no stdrd no stdrd no sidrd OCPSF 2,427 #/day 0,942 Chloroform (c) 46 21 0.417 0.190 Federal no stdrd '':470.00 no sidrd 861024.84 no sidrd 14350.414 OCPSF 0,417 Ji/clay 0,190 2 -Chlorophenol 98 31 0.887 0.281 Federal no stdrd 150.00 no stdrd #REFI no stdrd #REFI #REFI #REFI #REFI #REFI Chrysene (c, PAH) 59 22 0.534 0.199 Federal no sidrd 0.0180 no stdrd 32.98 no stdrd 0.550 OCPSF 0.534 #/day 0.199 Dl -n -butyl phthalate 57 27 0.516 0.244 Federal no sidrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.516 #/day 0,244 1,2 -Dichlorobenzene 163 77 1.476 0.697 Federal no stdrd 17000.00 no stdrd 4354741.94 no sidrd 72579.032 OCPSF 1.476 it/day 0,697 1,3 -Dichlorobenzene 44 31 0.396 0.281 Federal no stdrd 960.00. no stdrd 245914.84 no stdrd 4098 581 OCPSF 0,398 #/day 0,281 1,4 -Dichlorobenzene 28 15 0.254 0.136 Federal no stdrd 2600.00'P: no stdrd 666019.35 no sidrd 11100 323 OCPSF 0,254 #/day 0,136 1,1-Dichloroethane (c) 59 22 0.534 0.199 Federal no stdrd nostdrd- no stdrd no stdrd no stdrd nostdrd OCPSF 0534 #/day 0,199 1,2-Dichloroethane (c) 211 68 1.910 0.616 Federal no sidrd 3.70 no stdrd 6778.28 no sidrd 112.971 OCPSF 1,910 #/day 0.616 1,1-Dichloroethylene (c) 25 16 0.226 0.145 Federal no stdrd c-3.20- no stdrd 5862.30 no stdrd 97 705 OCPSF 0,226 #/day 0,145 1,2-trans-Dichloroethylene 54 21 0.489 0.190 Federal no stdrd 140000.00 nostdrd 35862580.65 no stdrd 597709677 OCPSF 0.489 #/day 0190 2,4-Dichlorophenol 112 39 1.014 0.353 Federal no stdrd 290.00 no stdrd #REFI no stdrd #REFI #REFI #REFI #REFI #REFI 1,2-Dichloropropane 230 153 2.083 1.385 Federal no sidrd 15.00 no sidrd 3842.42 no stdrd 64.040 OCPSF 2,083 #/day 1,385 1,3-Dichloropropylene (c) 44 29 0.398 0.263 Federal no stdrd 1700.00 no stdrd 3114345.16 no stdrd 51905 753 OCPSF 0,398 #/day 0,263 Diethyl phthalate 203 81 1.838 0.733 Federal no stdrd 44000.00 no stdrd 11271096.77 no stdrd 187851 613 OCPSF 1,838 #/day 0,733 2,4 -Dimethylphenol 36 18 0.326 0.163 Federal no stdrd 850.00 no stdrd 217737.10 no stdrd 3628 952 OCPSF 0.326 #/day 0.163 Dimethyl phthalate 47 19 0.426 0.172 Federal no stdrd 1100000.00 no stdrd 281777419.35 nostdrd 4696290.323 OCPSF 0.426 #/day 0.172 4,6-Dinitro-o-cresol (2 -Met 277 78 2.508 0.706 Federal no stdrd 280.00 no sidrd 71725.16 no sidrd 1195 419 OCPSF 2,508 #/day 0,706 2,4-Dinitrophenol 123 71 1.114 0.643 Federal no stdrd 5300.00 no sidrd 1357654.84 no sidrd 22627 581 OCPSF 1 114 #/day 0,643 2,4-Dinitrotoluene (c) 285 113 2.581 1.023 Federal no stdrd 3.40 no stdrd #REFI no sidrd #REFI #REFI #REFI #REFI #REFI 2,6-Dinitrotoluene (C) 641 255 5.804 2.309 Federal no stdrd - no stdrd no sidrd no sidrd no stdrd no stdrd OCPSF 5,804 #/day 2,309 Ethylbenzene 108 32 0.978 0.290 AQ/NOEC 325.000 '%29000.00.' 83252.42 7428677.42 1387.540 123811290 OCPSF 0,978 #/day 0,290 Flouranthene 68 25 0.616 0.226 Federal no sidrd 140.00 no stdrd 35862.58 nostdrd 597.710 OCPSF 0,616 #/day 0,226 Fluorene 59 22 0.534 0.199 Federal no stdrd 5300.00 no stdrd 1357654.84 no stdrd 22627581 OCPSF 0,534 #/day 0199 Hexachlorobenzene(c) 28 15 0.254 0.136 Federal no stdrd 2.90E-04 no stdrd 0.53 no stdrd 885E-03 CHRONIC 0,531 NgA Hexachiorobutadlene (c) 49 20 0.444 0.181 Federal no stdrd 18.00 no sidrd 32975.42 no stdrd 549.590 OCPSF 0 444 #/day 0 181 Hexachloroethane (c) 54 21 0.489 0.190 Federal no stdrd 3.30. - no stdrd 6045.49 no stdrd 100 758 OCPSF 0,489 #/day 0,190 Methyl Chloride 190 86 1.720 0.779 Federal no sidrd no stdrd -- no stdrd no stdrd no stdrd no sidrd OCPSF 1,720 #/day 0,779 Methylene Chloride (c) 89 40 0.806 0.362 Federal no sidrd 590.00 no stdrd 1080860.97 no stdrd 18014 349 OCPSF 0.806 #/day 0,362 Naphthalene 59 22 0.534 0.199 Federal no sidrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0,534 #/day 0,199 Nitrobenzene 68 27 0.616 0.244 Federal no stdrd 690.00 no sidrd 176751.29 no stdrd 2945 855 OCPSF 0,616 #/day 0,244 2-Nitrophenol 69 41 0.625 0.371 Federal no sidrd :no stdrd no stdrd no stdrd no sidrd no stdrd OCPSF 0,625 #/day 0,371 4-Nllrophenol 124 72 1.123 0.652 Federal no stdrd no stdrd no sidrd no stdrd mo stdrd no stdrd OCPSF 1.123 #/day 0.652 Phenanthrene 59 22 0.534 0.199 Federal no stdrd no sidrd no stdrd no stdrd no sidrd no sidrd OCPSF 0 534 #/day 0 199 Phenol 26 15 0.235 0.136 Federal no stdrd 1700000.00 no stdrd 435474193.55 no stdrd 7257903 226 OCPSF 0,235 #/day 0,136 Pyrene 67 25 0.607 0.226 Federal no stdrd 4000.00 no stdrd 1024645.16 no stdrd 17077 419 OCPSF 0,607 #/day 0,226 Tetrachloroethylene (c) 56 22 0.507 0.199 Federal no stdrd 3.30 no sidrd 6045.49 no stdrd 100.758 OCPSF 0,507 #/day 0,199 Toluene 80 26 0.724 0.235 Stale/AQ 11.000 200000.00 2817.77 51232258.06 46.963 853870966 OCPSF 0,724 #/day 0235 1,2,4-Tdchlorobenzene 140 68 1.268 0.616 Federal no stdrd 940.00 no stdrd 240791.61 no stdrd 4013194 OCPSF 1,268 #/day 0,616 1,1,1 -Trichloroethane 54 21 0.489 0.190 Federal nostdrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.489 #/day 0.190 1,1,2-tdchloroethane (c) 54 21 0.489 0.190 Federal no stdrd 16.00 no stdrd 29311.48 no stdrd 488,525 OCPSF 0,489 #/day 0,190 Trichlororethylene (c) 54 21 0.489 0.190 State no stdrd 30.00 no stdrd 54959.03 no stdrd 915.984 OCPSF 0,489 #/day 0,190 Vinyl Chloride (c) 268 104 2.427 0.942 State no stdrd 530.00 no stdrd 970942.90 no stdrd 16162.382 OCPSF 2.427 #/day 0.942 "Total Chromium 2770 1110 0.000 0.000 State 50.000 no stdrd 12808.06 no stdrd 213.468 no stdrd OCPSF 0.000 #/day 0.000 " Total Copper 3380 1450 0.000 0.000 Action level 7.000 no sidrd 1793.13 no stdrd 29.885 no sidrd OCPSF 0.000 #/day 0.000 Total Cyanide 1200 420 0.000 0.000 State 5.000 no stdrd 1280.81 no stdrd 21.347 no stdrd OCPSF 0.000 #/day 0.000 " Total Lead 690 320 0.000 0.000 State 25.000 no sidrd 6404.03 no stdrd 106.734 no stdrd OCPSF 0.000 #/day 0.000 " Total Nickel 3980 1690 0.000 0.000 Stale 88.000 no stdrd 22542.19 no stdrd 375.703 no stdrd OCPSF 0.000 #/day 0.000 Total Zinc' 2610 1050 0.000 0.000 Action level 50.000 50.00 12808.06 12808.06 213.468 213.466 OCPSF 0.000 #/day 0.000 'Total Zinc for Rayon Fiber Manufacture "Metals should only be limited if Total metal bearing wasteilor 01 00 that uses the viscose process and Acrylic process contains metal bearing wasleflow. Fiber Manufacture that uses zinc Cyanide should only be limited If Total cyanide bearing tvastef 0.00 chloridelsolvent process is 6,796 ug/L and process contains cyanide bearing wasleflow. 3,325 ug/L for maximum for any one day and maximum for monthly average, respectively. 12/12/2006 1 [Fwd: [Fwd: PFOA]] Subject: [Fwd: [Fwd: PFOA]] From: Kent Wiggins <kent.wiggins@ncmail.net> Date: Wed, 16 May 2007 11:51:26 -0400 To: Teresa Rodriguez <teresa.rodriguez@ncmail.net> CC: Pat Donnelly <Pat.Donnelly@NCMail.Net> Teresa, We have done a fair amount of research on the PFOA issue. There is currently no officially recognized method for this analysis. We discussed the analysis with our auditors and were able to find one lab that advertises the capability. Please see Pat Donnelly's attached email. Please let me know if you need anything else. Kent Subject: [Fwd: PFOA] From: Pat Donnelly <pat.donnelly@ncmail.net> Date: Wed, 16 May 2007 10:37:56 -0400 To: Kent Wiggins <Kent.Wiggins@ncmail.neU CC: Dana Satterwhite <dana.satterwhite@ncmail.neU, Gary Francies <Gary.Francies@ncmail.net> Kent, I believe this is where this issue stands. NC certified Lab #358, STL Denver advertises PFOA `-- --r--- - —..___ _-..- analysis on their WEB site. They also hold NELAP certification. I'm sure there are other labs that also do PFOA analysis. There's no currently promulgated EPA method for PFDA. Pat Subject: PFOA From: Teresa Rodriguez <teresa.rodriguez@ncmail.net> Date: Wed, 16 May 2007 10:13:23 -0400 To: kent.wiggins@ncmail.net CC: pat.donnelly@ncmail.net, Gil Vinzani <gil.vinzani@ncmail.net> Kent, we talked a couple of weeks ago about the situation with the DuPont permit and the monitoring of PFOA but I'm not sure we determined what they need to do regarding lab certification. We are ready to issue the DuPont permit which will include monitoring for PFOA. Is there anything we can include as a footnote or in the letter to DuPont regarding the analytical method or requirements for lab certification? Thanks, Teresa Teresa Rodriguez, P.E. Division of Water Quality EAST NPDES Program 919-733-5083 ext. 553 �� i ��1t� ���� � �e�4 _- ._..,. nr� � �',, Content -Type: message/rfc822 Content -Encoding: 7bit - __ PFOA' Content -Type: message/rfc822 Content -Encoding: 7bit 11'1 � U ��U`.n,. 1 of 1 5/16/2007 12:59 PM 3I. �(ad OAAe 0 epi -eb Carr �r Ojo S . mokt A Anj �,,r% 002. 11NITE® STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 t I I) 2Q01 Ms. Teresa Rodriguez North Carolina Department of Environment and Natural Resources Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, NC 276994617 SUBJ: Draft NPDES Permit DuPont Fayetteville Works - NPDES No. NC0003573 Dear Ms. Rodriguez: In accordance with the EPA/NCDENR MOA, we have completed review of the draft permit referenced above and have no comments. We request that we be afforded an additional review opportunity only if significant changes are made to the draft permit prior to issuance, or if significant comments objecting to the draft permit are received. Otherwise, please send us one copy of the final permit when issued. If you have any questions, please call me at (404) 562-9304. .�iu�c7'e y � Marshall Hyatt, Environmental Scientist Permits, Grants, and Technical Assistance Branch Water Management Division Internet Address (URL) ®http://v�vw✓.epa.gov Recycled/Recyclable ®Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) Draft NPDES Permit NC0003573 Subject: Draft NPDES Permit N00003573 From: Michael E Johnson <Michael.E.Johnson@USA.dupont.corry Date: Tue, 2 Jan 2007 10:29:22 -0500 To: teresa.rodriguez@ncmail.net Teresa: I received the draft NPDES permit you sent me. I have two questions for you: Question 1: I noticed that on the Outfall 002 page, the frequency of instream monitoring of conductivity changed from weekly to monthly, yet all the other instream parameters stayed at the weekly frequency. Was the conductivity frequency inadvertently .changed to monthly and should have remained as weekly? � r. Question 2: We are members of the Middle Cape Fear River Basin Association (MCFRBA) which is a coalition of dischargers in the middle section of the I�/_�,� Cape Fear River basin. Through the MCFRBA we contract a commercial � �i�'� /' laboratory to perform instream monitoring of the river at various locations � �� as dictated by an MOA between DWQ and MCFRBA. As such, under our existing NPDES permit, the instream monitoring requirement is waived as long as we / remain members of the MCFRBA. That waiver was specified in Note 1 in condition A(5). In the draft you sent me, I cannot find this waiver. Was this an advertent omission, or has DWQ changed their policy to allow coalition monitoring to satisfy the instream monitoring requirement? Let me know the answers to these questions and whether or not I need to formally send these as official comments to your office. Regards, Mike Michael E. Johnson Environmental Manager DuPont Company Fayetteville Works (910) 678-1155 This communication is for use by the intended recipient and contains information that may be Privileged, confidential or copyrighted under applicable law. If ��ou are not the intended recipient, you are hereby formally notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously designated as "E -Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact information for direct marketing purposes or for transfers of data to third parties. Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean http://wwca.DUPont.com/corp/email_disclaimer.html 1/4i2nm �•nt p� ,NORTH CAROLINA Cumberland County Public Notice S'FA1T? OF NOR1H CAROLINA ENVIRONMENTAL. MANAGEMENT COKMISS10N/NPDES -UNIT 161.7 MAIL SERVICE CENTER RALRIGFI NC 27699-1b11 NOTIFICATION OF INTENT TO ISSUE A NPDES WASTEWATER PERMIT )n the basis of thorough. tuff review- and application f NC General, Statute and regulations, the North Carolina Environmental Management Commission drooppooses to issue a National YollmAur Discharge Elbows. tion System (NPDES) .waste - water di.FcharRe. hermit to effective 45 days fr om the publi;h date of.dtis nodge: Written comments regardingg the proposed. permit .will be accepted uutil 30 days after the piublish Osie 'of tbis+ lto- tice. All comments received prior to that date ars consid eyed to the fnlal detM ina. tions .regarding. the pro- posed Demur. The Director 9P the NC Division, u1 Water Quality may decide to boll a public meed , for the pro - posed permit shouldthe Dim vimon receive a significant degree ofpiubuc init@jest. Cop�'es of the draft Permit Ing other $upporting tnfor; mallon on. useJ '.to deter - mine conditions present in fie. drag perrpit arc ayailahle spun request and payment of the .cosis ofrzprodnction. Mail commenu and/or re- quests for information to :the NC Diyisibn of Water Quality at the above address or call the; Point. Source Branch at ;919) 733-5983; extension. 563. Comments can also be e-mailed to: Carolyn,Btyant@pomaii,net Please include the :NPDFS permit number (attached) in any communication. Inter- e4ted poisons may also visit the Division of WaterQuality at 512 N. Salisbury Street, Raleigh NC 27664-1148 be- Iween the hours of 8:00 a.m. and 5,:00 p.m. to review io- formation on. file, Dupont Fayetteville Works, 225281mlighwayy 87 W., Fayetteville, NC 28106, Bladen Cost" has a lied for teneWal of its NPDIff dis- mre Cape .Fear River. interrtal antfall b01 oischar es a mezinmm df 2,0. MGD of treated process wastewater. No pammeters ate .currently water quality limite it 7;his discharge may impact form allocation of the+ receiving stream 120 829200 AFFIDAVIT OF PUBLICATION A eierore the unaersignea, a Nary otI'unrnc of said County and s a et du commissioned and authorized to administer oaths, affirmations, etc., personally appeared. CINDY L. OROZCO Who, being duly sworn or affirmed, according to law, doth depose and say that he/she is LEGAL SECRETARY of THE FAYETTEVILLE PUBLISHING COMPANY, a corporation organized and doing business under the Laws of the State of North Carolina, and publishing a newspaper known as the FAYETTEVILLE OBSERVER, in the City of Fayetteville, County and State aforesaid; and that as such he/she makes this affidavit; that he/she is familiar with the books, files and business of said Corporation and by reference to the files of said publication the attached advertisement of CL Legal Line DUPONT/NC0003573 of NCDENR/DWQ/NPDES Us inserted in the aforesaid newspaper in space, and on dates as follows: 12/27/2006. and.at the time of such. publication The. Fayetteville Observer was a newspaper meeting all the requirements and qualifications prescribed by Sec. No. 1-597 G.S. of N.C. The above is correctly copied from the books and files of the aforesaid corporation and publication. T LEGAL SECRETARY Sworn or affirmed to, and subscribed before me, this 4 day January, A.D., 2007. In Testimony Whereof, I have hereunto set my -hand and affixed my official seal, the day and year aforesaid. My commission expires 9th day of March, 2009, MAIL TO: NCDENR/DWQ/NPDES 1617 MAIL SERVICE CENTER, , RALEIGH, NC 27699 0000829200 Ms. Teresa Rodriguez NCDENR Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699 - 1617 �,� (� , 1 __... - ��;�: I � t.t.��.itJ r r �` t(ur�;Ci�' '''�+ i SUBJECT: NPDES Permit Renewal Application Addendum Revised Supplemental Information NPDES Permit No. NC0003573 Dear Ms. Rodriguez: �uPont Fluoroproducts 22828 NC Highway 87 W (Fayetteville, NC 28306-7332 December 7, 2006 Enclosed you will find a revised Supplemental Information document that describes the proposed changes with the construction of a new manufacturing unit that will produce Polyvinyl Fluoride (PVF) polymer resins. It has been determined that the preferred means of controlling solids from the PVF unit is via the site's central wastewater treatment plant. Accordingly, treated wastewater from this new unit will be discharged through and monitored at Outfa11001. A revised water balance sheet is enclosed which reflects the above treatment change. Should you have any questions, please feel free to call me at (910) 678-1155. Sincerely, Michael E. Johnson Environmental Manager Enclosures E.I. du Pont de Nemours and Company DuPont Company — Fayetteville Works NPDES Permit No. NC0003573 Supplemental Information (Revised) Revised Supplemental Information — Permit Renewal Application — December 7, 2006 Proposed Changnes in Operations PVF Manufacturing Facility: The DuPont Company —Fayetteville Works has been selected as the location for the DuPontTM Polyvinyl Fluoride (PVF) manufacturing process. The manufacturing facility is in the process of being designed, and will produce PVF polymer resins. PVF resin to be manufactured at the Fayetteville plant is used in DuPontTM Tedlar® fluoropolymer film business. Tedlar® film is manufactured at other DuPont site location (not the Fayetteville plant). Tedlar® is used in the photovoltaic industry in photovoltaic cells and the aircraft industry for interior cabin surfaces, as well as many other uses. This new facility construction will be completed in August 2007 and begin start up in October 2007. The manufacturing facility will be located near the existing Teflon® FEP resin manufacturing area. This process will produce polyvinyl fluoride (PVF) resin (CAS No. 2498144-4). The process wastewater from the PVF Manufacturing Facility will be conveyed to the site's central wastewater treatment plant, which will properly control any solids that are discharged from the process. The treated wastewater from the PVF Manufacturing Facility will be discharged through and monitored at Outfall 001. A suggested change to the language of the current permit's narrative in the "Supplement To Permit Cover Sheet" that would accommodate the new PVF Manufacturing Facility follows: 1. Continue to operate existing wastewater treatment facilities consisting of: • equalization; (etc) 2. Discharge treated process wastewater fr om Butacite®, Nafion®, PVF, and Teflon® PMDF, process stormwater, sanitary wastewater, and co -neutralized regenerate from said treated facilities through internal outfall 001; The process wastewater is expected to contain unreacted vinyl fluoride (CAS No. 00075-02-5). The anticipated quantity of vinyl fluoride from the PVF Manufacturing Facility is 0.312 pounds per day. This quantity would equate to approximately 0.04 mg/L vinyl fluoride at Outfall 001 and 0.0035 mg/L vinyl fluoride at Outfall 002. Finally, non -contact cooling, condensate, and stormwater from the PVF Manufacturi ng Facility will be discharged directly to Outfa11002 via the site's Woodlined Ditch6 Date: November 275 2006 To: Teresa Rodriguez Environmental Engineer, Central Office Thru: Belinda Henson K /t , Regional Supervisor, Fayetteville Regional Office Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources From: Marls Brantley Environmental Chemist, Fayett ille Regional Office Alan W. Klimek, P.E. Director Division of Water Quality DEC 1 2006 Subject: Amendment to the Dupont Staff report for the NPDES Permit Renewal Dupont's Fayetteville Worlcs will be adding a new manufacturing process in the fall of 2007. The manufacturing unit will produce Polyvinyl Fluoride (PVF) polymer resins. Dupont has determined that the preferred means of controlling solids from the PVF unit is a new clarifier, which will be dedicated to the PVF wastewater. The discharge from this clarifier will be to the existing Outfall 001. This design replaces the original submittal's description of the PVF treated wastewater being discharged through and monitored at Outfall 006, It is the recommendation of the Fayetteville Regional Office that NPDES Permit No. NC0021636 be issued for the wastewater treatment plant. The subject application for permit renewal should be processed in keeping with basinwide strategy. One NorthCarolina �lltlilYl��f North Carolina Division of Water Quality 225 Green Street -Suite 714 Fayetteville, NC 25301 Phone (910) 486-1541 Customer Service Internet: www.ncwaterqualityorg Fax (910)486-0707 1-877-623-6745 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper LAW 13,( Form 2C, Part III B: WATER BALANCE (Revised 12/07/06) DuPont Company - Fayetteville Works Flows Unit: Gallons per Day Basis: All Production Manufacturing, using DIVISION OF WATER QUALITY May 30, 2006 MEMORANDUM Ip IA TO: G 1,Vinzani, Supervisor NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 FROM: Mark Brantley, Environmental Chemist �� %� Fayetteville Regional Office THRU: Belinda S. Henson, Water Quality Supervisor 4LY Fayetteville Regional Office SUBJECT: NPDES Staff Report and Recommendations NPDES Permit No. NC0003573 DuPont WWTP Bladen County Please find attached the staff report and recommendations ofthe Fayetteville Regional Office concerning the renewal of subject NPDES Permit. If you have any questions or require any further information, please advise:-;� ��.. Attachment SOC PRIORITY PROJECT: YES_ NO X If Yes, SOC No. To: Permits and Engineering Unit Surface Water Protection Section Attention: Gil Vinzani Date: _ May 30, 2006 "i tf r NPDES STAFF REPORT AND RECOMMENDATION COUNTY* Bladen � Permit No. NC 0003573It � PART I -GENERAL INFORMATION 1. Facility and Address: DuPont Fayetteville Works 22828 NC Hwy 87 W Fayetteville, NC 28306 3. C! 5 6. fll E 9. Date of Investigation: Report Prepared by: May 18, 2006 Mark Brantley, Environmental Chemist Persons Contacted and Telephone Number: It , Robert Geddie, ORC 910-678-1219 Michael Johnson, Environmental Manager Fayetteville Works 910-678-1155 Directions to Site: This facility is located at the Bladen -Cumberland County line, between Highway 87 and the Cape Fear River. Discharge Point(s), List for all discharge points: Latitude: 340 49'5211 Longitude: 78° Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map. U.S.G.S. Quad No. H 23 -SE U.S.G.S. Quad Name: Duart, NC Site: Land available for expansion and upgrading: YES, DuPont owns approximately 2,600 acres at this site. Topography and relationship to flood plain: Relatively flat. Location of nearest dwelling: None within 1,0001 Receiving stream or affected surface waters: Cape Fear River PART I - GENERAL INFORMATION -(continued) bM cA Classification: Class C River Basin and Subbasm No.: Cape Fear River Basin 03 - 06 - 17 Describe receiving stream features and pertinent downstream uses: The flow from the combined waste discharge from this facility flows through a wood lined channel installed as an effluent and storm water conveyance. This combined flow discharges over a fabricated formed concrete lined ditch until velocities are diminished and from there to the remainder of the effluent channel. Under normal (dry) conditions, this facility produces the flow in the effluent channel. The Cape Fear River is located approximately 2,500 feet downstream. (The discharge point has historically been indicated as the main stem of the Cape Fear River.) PART II -DESCRIPTION OF WASTES AND TREATMENT WORKS 1. a. Volume of wastewater to be permitted: 2.0 MGD b. What is the current permitted capacity of the Wastewater Treatment facility? 2.0 MGD c. Actual treatment capacity of the current facility (current design capacity). 2.0 MGD d. Dates) and construction activities allowed by previous Authorizations to Construct issued in the previous two (2) years. N/A e. Please provide a description of existing or substantially constructed wastewater treatment facilities: Process wastewater and storm water from the various manufacturing areas are collected in the respective area sumps and ultimately conveyed via a gravity flow underground process sewer pipe to the site's central wastewater treatment plant (WWTP). Sanitary sewage is conveyed via a separate underground sewer system to the WWTP. The permitted flow rate of the WWTP is 2.0 MGD, with an actual average flow rate of approximately one MGD. This process wastewater is commingled in the WWTP Influent Sump where it is pumped to an 850,000 -gallon Equalization Basin. The Equalization Basin is mixed with two floating mixers. Three floating surface aerators in the basin cool and aerate the incoming wastewater. A 175,000 -gallon Emergency Retention Tank is available for temporary storage of the wastewater which may need additional treatment or acclimation in the WWTP activated sludge process at a controlled rate that allows for proper biological treatment. Wastewater fr om the Equalization Basin is normally pumped to a 250,000 -gallon Predigester Tank in which initial biological activity with the WWTP activated sludge begins. The Predigester Tank is aerated. The partially treated wastewater from the Predigester Tank is pumped to a 1,700,000 -gallon Aeration Tank. The Aeration Tank is the site of the majority of the biological activity. The Aeration Tank is aerated primarily by a diffused air system located in the bottom of the tank. The tank can have supplemental aeration via a floating Biomixer that injects air through submerged rotors. (However this system is currently broken and has been removed from the aeration tank. Portable blowers have been brought in to aerate the tank.) 2 4. PART H - DESCRIPTION OF WASTES AND TREATMENT WORKS -(continued) The biologically treated wastewater is then sent to two in -ground clarifiers (119,000 gallons and 168,000 gallons respectively) in parallel. The clarified treated effluent is discharged to and through Outfall 0014 The wasted sludge is sent to a Dissolved Air Floatation (DAF) unit, then to a 47,000 gallon Sludge Storage Tank, and finally to Rotary Filter for thickening. The thickened sludge is dewatered in a Sludge Press, and can be dried in a steam -heated dryer for additional moisture removal. The dewatered and/or dried sludge is transported off-site to a commercial Subtitle D landfill. Non -contact process cooling water and non -process storm water are conveyed via surface ditches to the site's Woodlined Ditch. In addition, excess river water flow and Outfall 001 effluent are discharged directly to the Woodlined Ditch. The combined, total flow of water from the site is discharged and monitored at Outfall 002. The Outfall 002 maximum 30 -day average flow was 16.3 MGD during the period from 2005-2006. Flow variability at Outfall 002 is from 3.0 to 18.6 MGD, however, flow can consistently be in the 16.3 MGD range. £ Please provide a description of proposed wastewater treatment facilities: Please see Attachment A for a detailed description for "Proposed Changes in Operations" g. Possible toxic impacts to surface waters: N/A h. Pretreatment Program (POTWs only): Tn development Approved Should be required Not needed X Residuals handling and utilizing/disposal scheme: a. If residuals are being land applied, please specify DWQ Permit No. Permit Number Residual Contractor: Telephone b. Residuals stabilization: PSRP PFRP Other c. Landfill: The dewatered and/or dried sludge is transported off-site to a commercial Subtitle D landfill. This sludge is currently being disposed of at the Waste Industries' Sampson County Landfill near Roseboro, NC. d. Other disposal/utilization scheme (specify): Treatment plant classification (attach completed rating sheet): Grade III SIC Code(s): Primary. Secondary Main Treatment Unit Code: PART III- OTHER PERTINENT INFORMATION 1 2. 3 4. 5 Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? Special monitoring or limitations (including toxicity) requests: Monitoring and limits should be in keeping with basinwide strategy. Important SOC, JOC, or Compliance Schedule Dates (please attach): N/A Date Submission of Plans and Specifications.................................................... N/A Begin Construction, . a a 0 0 * S 0 a a 6 a 0 a 0 a 6 0 W 0 0 5 0 9 0 0 0 0 T 0 0 9 1 d 0 a 9 1 4 4 4 8 a 1 0 a 0 0 a a a 0 0 0 d 0 a 8 * a 0 0 0 a V 0 0 9 N/A Complete Construction, . 0 a a 0 B 0 a 0 a 0 a a 0 a & a * a 0 6 0 0 * 5 9 9 0 0 N/A Alternative Analysis Evaluation: Has the facility evaluated all of the nondischarge options available? Please provide regional perspective for each option evaluated. Spray Irrigation: Not practical. Connection to Regional Sewer System: None Available. Subsurface: Not practical. Other disposal options: None lrnown. Other Special Items: There are 2 items of interest the Fayetteville Regional Office would like address. 1. The compound commonly known as "C8" (ammonium perfluorooctanoate.) has been in the media quite frequently in the recent past. This compound is currently manufactured only at the Fayetteville Dupont Works. It is noted in Dupont's application that the APFO Manufacturing site is where this chemical is made. It is also noted in the application (Attachment B) that all wastewater generated from this manufacturing facility is collected and shipped off-site for disposal. No process wastewater from this manufacturing facility is discharged to the site's biological WWTP or to the Cape Fear River. Due to C8 being detected in some of the monitoring wells on Dupont's site and the general public's concern over the health effects of C8, the Fayetteville Regional Office of the Division of Water Quality recommends a monitoring requirement only for C8 on the effluent for data collection and information purposes. 2. All discharges form this site ultimately go into the Woodlined Ditch, which collectively discharges into an effluent channel that discharges to the Cape Fear River. Over the years the flow of the effluent through the channel has significantly eroded the banks and has carried and deposited the sediment in the Cape Fear River forming a Delta like structure. It is apparent from a meeting on March 10, 2006 with Mike Johnson, Environmental Manager for Dupont's Fayetteville Works, that Dupont acknowledges that their effluent channel has and continues to cause sediment to be deposited into the Cape Fear River and is willing to address this issue. This is a very significant matter as the Company has benefited from this PART III- OTIIER PERTINENT INFORMATION -(continued) effluent channel for some years and needs to address this issue soon. As per a phone conversation with Mike Johnson it was understood that stream studies were about to begin to determine the best place to relocate the outfall line. This office requests that DuPont provide to Fayetteville Regional Office of the Division of Water Quality a definite plan of action (to be incorporated into this permit or other administrative mechanism) to address this issue. PART IV -EVALUATION AND RECOMMENDATIONS It is the recommendation of the Fayetteville Regional Office that NPDES Permit No. NC0021636 be issued for the wastewater treatment plant. The subject application for permit renewal should be processed in keeping with basinwide strategy. Sign Report Preparef Lei 3 Yw� t%rL) Water Quality Regional Supervisor DuPont Company – Fayetteville Works NPDES Permit No. NC0003573 Supplemental Information Proposed Changes in Operations PVF Manufacturing Facility: The DuPont Company –Fayetteville Works has been selected as the location for the DuPontTM Polyvinyl Fluoride (PVF) manufacturing process. The manufacturing facility is in the process of being designed, and will produce PVF polymer resins. PVF resin to be manufactured at the Fayetteville plant is used in DuPontTM Tedlar® fluoropolymer film business. Tedlar® film is manufactured at other DuPont site location (not the Fayetteville plant). Tedlar® is used in the photovoltaic industry in photovoltaic cells and the aircraft industry for interior cabin surfaces, as well as many other uses. This new facility construction will be completed in August 2007 and begin start up in October 2007. The manufacturing facility will be located near the existing Teflon® FEP resin manufacturing area. This process will produce polyvinyl fluoride (PVF) resin (CAS No. 24981444). As with most fluorochemical processes, the wastewater from the PVF manufacturing process is expected to have very little or no biological oxygen demand (BODS) value. Treatability tests have been performed on samples from another DuPont site which currently manufactures PVF. These studies have indicated use of non -biological treatment will meet effluent limitation of OCPSF NSPS guidelines of Subpart D—Thermoplastic Resins (40 CFR 414.40). DuPont proposes to discharge the treated wastewaters from this new facility through a currently permitted outfall, designated as Outfall 006. The contact process wastewater and stormwater will be treated with solids separation technology prior to discharging to the outfall. A suggested change to the language of the current permit's narrative for Outfa11006 that would accommodate the new PVF Manufacturing Facility follows: "Beginning on the effective date of this permit and lasting through the expiration date, the Permittee is authorized to discharge from Outfa11006 (Polyvinyl fluoride Manufacturing Facility low -biodegradable process wastewaters). Such discharges shall be limited and monitored by the Permittee as specified below:" The process wastewater is expected to contain unreacted vinyl fluoride (CAS No. 00075-02-5). The anticipated quantity of vinyl fluoride from the PVF Manufacturing Facy is 0.312 pounds per day. This quantity would equate to 0.9 mg/L vinyl fluoride at Outfall 006 and 0.0035 mg/L vinyl fluoride at Outfall 002. Finally, non -contact cooling, condensate, and stormwater from the PVF Manufacturi ng Facility will be discharged directly to Outfall 002 via the site's Woodlined Ditch. DuPont Company — Fayetteville Works Current Operating Conditions NPDES Permit No. NC0003573 Supplemental Information Butacite® Manufacturing: The DuPont Company — Fayetteville Works' Butacite® manufacturing area produces two final products. DuPontTM Butacite® Interlayer plastic sheeting is the final product used in safety glass such as automobile windshields. Polyvinyl butyral (PVB) resin is shipped off-site as a transfer to other DuPont locations for final processing. Wastewater generated from this manufacturing facility is treated in the site's biological wastewater treatment plant (WWTP). Nafion® Manufacturing: The DuPont Company — Fayetteville Works' Nafion® manufacturing area produces five final products. DuPontTM Nafion® Membrane is a plastic film used in the chloroalkali industry and in electrochemical fuel cells. Nafion® Resins are ultimately extruded into a finished film. The FLPR Vinyl Ether and HFPO monomers are shipped to other DuPont locations to produce various fluorochemical products such as DuPontTM Teflon®. Wastewater generated from this manufacturing facility is neutralized and discharged to the WWTP. Teflon® Manufacturing: The DuPont Company —Fayetteville Works' PMDF Teflon® manufacturing area produces DuPontTM Teflon® FEP resin. Teflon® FEP resin is used in the electronics industry as a coating for wire, as well as many other uses. This facility was constructed in 1999-2000 and was started up in December 2000. Wastewater generated from this manufacturing facility is treated in the'WWTP. APFO Manufacturing: The DuPont Company —Fayetteville Works' APFO manufacturing area produces ammonium perfluorooctanoate. The APFO produced in this unit is used to produce fluoropolymers and fluorinated telomers, but none of the produced APFO is used at the Fayetteville Works site. This facility was started up in November 2002. All wastewater 9 r__ �1_.0 _---... r 'y. . r e1•: &44 . . _ SentryGlas® Plus Manufacturing: The DuPont Company —Fayetteville Works' SentryGlas® Plus manufacturing area produces DuPontTM SentryGlas® Plus Tonoplast interlayer laminate. SentryGlas® Plus interlayer is used for laminated safety glass in side, rear, and overhead automobile windows. It is also used in architectural applications desiring safety glass. This facility was started up in June 2005. There is no contact process wastewater generated from this manufacturing facility, therefore only sanitary waste from this area is treated in the WWTP. This manufacturing facility does discharge non -contact cooling water to the woodlined ditch and ultimately to Outfall 002. Ms. Teresa Rodriguez NCDENR Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699 - 1617 SUBJECT: NPDES Permit Renewal Applicat�� Revised Form 2C and Supplemental NPDES Permit No. NC0003573 Dear Ms. Rodriguez: Addendum on DuPont Fluoroproducts 22828 NC Highway 87 W Fayetteville, NC 28306-7332 August 2, 2006 DE:NR •'h`ATE� QUAIIiY i'rJ�? �Oi�RCE t36a;AC�CN Enclosed are the revised Form 2C submittals for the subject renewal application. These forms include the omitted analytical data. Outfall 002 sampling showed unexpected positive results for cyanide, chloroform, dichlorobromomethane, and bis(2-ethylhexyl)phthalate; none of which are used or produced at this site. Also, you will find a revised Supplemental Information document that describes the proposed changes with the construction of a new manufacturing unit that will produce Polyvinyl Fluoride (PVF) polymer resins. It has been determined that the preferred means of controling solids from the PVF unit is a new clarifier which will be dedicated to the PVF wastewater. The discharge from this clarifier will be to the existing Outfall 001. Therefore, please ignore the original submittal's description of the PVF treated wastewater being discharged through and monitored at Outfa11006. A revised water balance sheet is enclosed which reflects the above treatment change. Should you have any questions, please feel free to call me at (9101 678-1155. Enclosures E.I. du Pont de Nemours and Company Michael E. Johnson Environmental Manager DuPont Company – Fayetteville Works NPDES Permit No. NC0003573 Supplemental Information (Revised) Revised Supplemental Information – Permit Renewal Application – August 1, 2006 Prouosed Changes in Operations PVF Manufacturing Facility: The DuPont Company – Fayetteville Works has been selected as the location for the DuPontTM Polyvinyl Fluoride (PVF) manufacturing process. The manufacturing facility is in the process of being designed, and will produce PVF polymer resins. �. PVF resin to be manufactured at the Fayetteville plant is used in DuPontTM Tedlar® fluoropolymer film business. Tedlar® film is manufactured at other DuPont site location (not the Fayetteville plant). TedlarO is used in the photovoltaic industry in photovoltaic cells and the aircraft industry for interior cabin surfaces, as well as many other uses. This new facility construction will be completed in August 2007 and begin start up in October 2007. The manufacturing facility will be located near the existing Teflon® FEP resin manufacturing area. This process will produce polyvinyl fluoride (PVF) resin (CAS No. 24981-14-4). As with most fluorochemical processes, the wastewater from the PVF manufacturing process is expected to have very little or no biological oxygen demand (BODS) value. Treatability tests have been performed on samples from another DuPont site which currently manufactures PVF. These studies have indicated use of non -biological treatment will meet effluent limitation of OCPSF NSPS guidelines of Subpart D—Thermoplastic Resins (40 CFR 414.40). DuPont will control solids in the wastewater from this new facility via a new dedicated clarifier whose ,> discharge will go directly to Outfall 001. A suggested change to the language of the current permit's narrative in the "Supplement To Permit Cover Sheet" that would accommodate the new PVF Manufacturing Facility follows: 1. Continue to operate existing wastewater treatment facilities consisting of: • equalization; (etc) 2. To operate new wastewater treatment facilities consisting of: • clarifier for PVF process wastewater; 3. Discharge treated process wastewater from Butacite, Nafion, PVF, and Teflon® PMDF, process stormwater, sanitary wastewater, and co -neutralized regenerate form said treated facilities through internal outfall 001; The process wastewater is expected to contain unreacted vinyl fluoride (CAS No. 00075-02-5). The anticipated quantity of vinyl fluoride from the PVF Manufacturing Facility is 0.312 pounds per day. This quantity would equate to approximately 0.04 mg/L vinyl fluoride at Outfall 001 and 0.0035 mg/L vinyl fluoride at Outfall 002. Finally, non -contact cooling, condensate, and stormwater from the PVF Manufacturi ng Facility will be discharged directly to Outfa11002 via the site's Woodlined Ditch.