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NORTH CAROLINA C8 WORKING GROUP
May 55 2006
Alan Klimek, Duector
Division of Water Quality _
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699Water Quality Division
RE: Request to Investigate DuPont's Fayetteville Plant for Deliberate Unauthorized Discharges
APFO Plant Wastewater
Dear Mr. Klimek,
Please consider this letter as enforcement sensitive and direct it to the appropriate persons within
your Division. This request concerns DuPont's Fayetteville facility, the only location in the
United States where APFO (also known as C8) is produced. As you may know, C8
contamination of groundwater and surface water at the Fayetteville Works was discovered several
months after production of this controversial chemical began. Since that time, C8 contamination
has been found in new areas of the plant and in off-site locations. The source(s) of this
contamination.has yet to be identified by DuPont or DENR
Although DuPont has represented that all APFO Plant wastewater was transported out of the
complex for off-site treatment and disposal, records to support this claim are not available to the
public. Ifunauthorized wastewater discharges did occur, it could explain the presence of C8
contamination in surface water discharges and monitoring wells located near the Wastewater
Treatment Plant. It could also explain the presence of C8 in the Nafion area and in groundwater
Lt the APFO plant.
Background
On May 3, 2001 DuPont -Fayetteville submitted a renewal application for its NPDES discharge
permit. The new permit was to authorize wastewater discharges from the new APFO Plant in
addition to existing permitted discharges from other plants in the complex. It was anticipated that
up to 48,000 gallons of APFO Plant wastewater would need to be discharged each day.(1)
DuPont wanted to be able to choose between two discharge options for the APFO Plant
wastewater. One option was to send it through the Wastewater Treatment Plant where it would
then be discharged with wastewater from other plants through a "woodlined ditch" leading to the
Cape Fear River. The other option was to bypass the Wastewater Treatment Plant, and the send
the APFO Plant wastewater to the Cape Fear River through the woodlined ditch.(2)
On January 9, 2004 DuPont was sent the NPDES permit authorizing discharges fr
om the APFO
Plant.(3) The permit was to be effective as of February 1, 2004 and did not require the
wastewater to be monitored for C8. It allowed DuPont the option of bypassing the Wastewater

Treatment Plant when it chose to do so. Even though DuPont was granted the permit it had been
requesting since May of 2001, the company promptly notified DENR that it no longer wanted
authority to discharge APFO Plant wastewater. The DENR changed the permit accordingly on
February 3, 2004 and references to Outfall 007 and APFO Plant discharges were removed.
DuPont began operating its APFO Plant in late 2002, well before it received the permit,
authorizing APFO plant discharges. Discharges occurring before the effective date of the permit
would have been a clear violation of the Clean Water Act, as would have been discharges
occurring after the permit was changed on February 3, 2004. DuPont claims that it has never
discharged wastewater from the APFO Plant. According to DuPont, all C8 wastewater has been
trucked to its facility in Deepwater, New Jersey, to a hazardous waste incinerator in El Dorado,
Arkansas, or to other locations.
For some reason DuPont chose the more expensive option of trucking its wastewater off-site and
out-of-state, over the less expensive option of discharging it to the Cape Fear River.(4) We
believe that it is possible that DuPont discharged APFO Plant wastewater when it first began C8
production and stopped doing so when it discovered or suspected C8 was escaping into
groundwater or surface water. DuPont claims its first sampling of groundwater for C8 took place
in January 2003.
DuPont had a possible economic incentive to begin discharging before receiving authorization to
do so. It was unlikely that APFO Plant discharges, mingled with discharges from other
manufacturing plants, would be noticed by the Division in the absence of specific sampling and
analysis. DuPont may also have assumed, and correctly so, that DENR would be issuing the
NPDES permit authorizing the discharges anyway.
The following indicates that deliberate unauthorized discharges may have occurred:
• When DuPont first applied for permission to discharge from the APFO Plant, the company
wanted to be able to by-pass the Wastewater Treatment Plant because fluoride and fluorocarbons
in the wastewater would cause settleability problems in the clarifiers. However, DuPont was also
concerned that APFO Plant wastewater that did not go through the Wastewater Treatment Plant
(WWTP) might exceed permit limitations for BOD. Accordingly, DuPont proposed to bypass the
WWTP unless BOD approached the permitted limits.
• In November of 2002, DuPont exceeded its permitted monthly discharge limits for BOD. This
was the first such exceedance in the site's thirty year history.(5) The exceedance resulted in a
slime appearing in the clarifiers.(6) When DuPont applied for their NPDES permit, the company
indicated that a yet to be identified Biocide would be used in the APFO Plant's scrubber.(7)
DuPont blamed the BOD exceedance of November 2002 on a new plasticiser that had been used
in the Butacite Plant without incident most of the year.
• Although DuPont would later inform the DENR that the APFO Plant did not begin operating
until November 23, 2002, a news article in the Fayetteville Observer, which included interviews
with the plant manager, states that the plant began producing C8 in October 2002.(8) The news
reporter could have been mistaken about the October startup date, but comments in a DENR
regional report also reflect a startup date of October of 2002.
• The same DENR inspection report that identified the APFO Plant start
up date of October 2002
also stated that the plant only operated for a couple of months before shutting down until June of

2003. If these dates are correct, this shut down would have occurred around January of 2003, the
same time DuPont claims to have first discovered C8 in groundwater and surface water
discharges. Perhaps this discovery prompted DuPont to stop unauthorized discharges and begin
trucking the wastewater off-site for disposal. DENR files contained records reflecting such
wastewater shipments in 2003, but not for 2002 when the APFO Plant first started operating.(9)
• DuPont claims that the C8 in groundwater at the Nafion Plant does not come from the APFO
Plant, but instead comes from the Nafion manufacturing process where it is created as a "by-
product." DuPont also claims this by-product leaked to the groundwater from an "underground
concrete waste storage vault, or sump" beneath the Nafion Plant. This area is referred to as
SWMU 6 (Common Sump). DuPont claims the sump was closed in 2000 after plant workers
found groundwater leaking through a in the crack in the floor.(10) This leak would have occurred
before the APFO Plant began operating. DuPont also reported a crack in the concrete wall near
the top of the "Waste Fluorocarbon System's secondary containment sump" on December 11,
2002. The APFO Plant was operating at this time. DuPont asked that its hazardous waste permit
be modified to allow this "existing secondary containment system" to be repaired and lined.(11)
• It is also possible that the C8 found in groundwater beneath the Nafion Plant came from
unauthorized APFO Plant wastewater discharges that were routed to the Nafion Plant, DuPont's
NPDES permit application proposed two locations for a new internal Outfall 007 to monitor
APFO Plant discharges. One was at the APFO Plant and the other was at the Nafion Plant.(12)
• Itis not clear if APFO Plant discharges were intended to enter the "Common Sump" prior to
discharge through Outfall 007, Even if APFO Plant wastewater did not enter the common sump,
the wastewater could still cause or contribute to the C8 contamination in the Nafion area. In 2004
the DENR noted, "the distribution of different constituents and variations in their concentrations
implies there may be more than one release originating at SWMU 6 (Common Sump)." The
agency wanted DuPont to consider the possibility of point sources of contamination "other than
the common sump at SWMU 6."(13)
Specific Areas and Events in Need of Investigation
• Pathways for Deliberate Wastewater Discharges
According to DuPont, there is a "drainage system" in the C8 plant that is "designed to catch and
guide any spilled material into a collection and treatment system.(14)" This collection and
drainage and collection system should be sampled for the presence of C8. Although DuPont
claims never to have discharged wastewater from the APFO Plant, it was apparently designed and
built on the assumption that discharges could occur.
The APFO Plant's drainage or conveyan
ce system should be sampled at the point beginning at
the APFO plant where DuPont initially proposed Outfall 007, and points leading to the Nafion
Plant where DuPont also proposed to locate Outfall 007.
DuPont employees, who would have knowledge of APFO Plant discharges, should be
interviewed to determine if APFO Plant wastewater discharges occurred. The interviews should
be conducted off-site and in the absence of DuPont management.
• Records of Wastewater Shipment and Disposal

The DENR should locate, review, and make public company records that verify the proper
shipping, treatment, and disposal of C8 contaminated wastes. DuPont has indicated APFO Plant
wastewater was trucked off-site. DuPont reported the shipment of hazardous wastes from the
APFO Plant for year 2003 including 754,158 lb of "sulfuric acid from C8 process WFN-221,"
14,718 lb of "APFO heels from dilution tank/sump ATN. 155A," and 6,894 lb of "APFO heels
from dilution tank WFN-155." These wastes were reported in the 2003 Biennial Report
submitted to EPA.
Even if reporting is required for odd years only, DuPont is required to keep records of waste
shipments for EPA to review. Records of waste haulers and the facilities where the waste was
shipped (NJD0002385730 and ARD069748192) should be checked to determine if wastes
generated in 2002 were received. EPA can also review production records to determine if the
amounts of wastes shipped correspond to the amounts produced.
We understand that documents related to enforcement investigations may not be available
to the public until the enforcement process is complete. However, we would like to know this
investigation is actually being conducted and we would like to see any evidence that wastewater
was, in fact, shipped off-site for 2002 and 2003. If the agency does not intend to investigate this
matter, we will ask others to do so.
Your attention to this matter is appreciated. Please direct your communications to the NC C8
Working Group at the address on the letterhead.
Yours truly,
Hope Taylor -Guevara' '
Exec. Director, can Water for North Carolina
[phone] or [e-mail]
c ove
Southeastern Repre
sentative, WATERKEEPERt� Alliance
[phone] or [e-mail]
References:
(1) Renewal Application for NPDES Permit NC0003573, May 3, 2001.
(2) DuPont's Schematic Water Flow Process Uses, revised 4/01. Page 2 of 2 indicates that
wastewater water from the APFO plant and the Nafion Processes could be routed through the
Wastewater Treatment Plant or directly to the Cape Fear River.
(3) NPDES Permit NC0003537. NPDES Renewal Application approved by DENR and Permit
NC0003573 effective 24-04 attached. Indicates discharge of treated wastewater from APFO and
other facilities through internal Outfall 001 and APFO low -biodegradable wastewater through

Outfall 007. Internal Outfalls 001, 006, and 007 are discharged through Outfall 002 at Cape Fear
River. Outfall 007 (APFO low -biodegradable process wastewater) limitations were: flow .048
MGD monthly average; BODS 20 degrees C, 18 lb. a day monthly average, 48 lb. day daily
maximum; TSS 22.81b./day monthly average, 73.3 lb./day daily maximum; pH between 6-9
standard units.
(4) On 2/3/04 DENR sent a corrected permit reflecting changes requested by DuPont, including
references to Outfall 007 where G8 plant discharges had previously been authorized.
(5) The 1/17/03 letter from DuPont to DENR blamed the exceedance on the use of a new
plasticizer in the Butacite Plant. According to DuPont, the plasticizer was used without issue for
most of 2002.
(6) 2/5/03, Letter from DENR to DuPont Fayetteville Works with December 5, 2002 internal
DENR email communication. According to an 3/21/03 EPA inspection report, DuPont blamed the
BOD exceedance of November 2002 on a new product (3GO Plasticide) that was discharged to
the wastewater treatment plant.
(7) 5-3-01, DuPont Renewal Application for NPDES Permit NC0003537, Potential Facility
Changes.
(8) "DuPont officials say chemical process is safe," March 3, 2003, Fayetteville Observer
(9) DuPont's 2003 Hazardous Waste Report, Forms GM, identify quantities of hazardous waste .
related to the GS manufacturing process and the ultimate location and disposition of those
wastes.
(10) 5/26/05, "DuPont monitors chemical pollution." Fayetteville Observer
(11) 12-11-02, Letter from DuPont's Fayetteville Plant Environmental Manager to DENR
Division of Waste Management, Hazardous Waste Section
(12) It is not clear why DuPont wanted to route the APFO Plant Wastewater to the Nafion Plant
area located several hundred yards to the south east. This was not the most direct route of
discharge to the Cape Fear River or the Wastewater Treatment Plant. Although DuPont proposed
that Nafion and APFO plant discharges have the same effluent limitations and monitoring
requirements, each had a separate internal Outfall to be monitored.
(13) 6/25/04, Hazardous Waste Section's Comments on Phase I Supplemental RCRA Facility
Investigation Report (5/27/04)
(14) 3/3/03, "DuPont officials say chemical process is safe," Fayetteville Observer

NCDENR
North Carolina Department of Environment and Natura
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 225 2011
Michael E. Johnson
Environmental Manager
Dupont — Fayetteville Works
22828 NC Hwy 87 West
Fayetteville, NC 28306-7332
Subject: BIOMONITORING INSPECTION
DuPont — Fayetteville Works
NPDES Permit No. NC0003573
Bladen County
Dear Mr. Johnson,
Resources
pee Freeman
Secretary
Enclosed you will find a copy of the Compliance Biomonitoring Inspection report for
the inspection that Danny Strickland (DW -Fayetteville Regional Office) and I conducted
on February 15 and 17, 2011. The inspection included the same objectives as that of a
routine Compliance Evaluation Inspection plus a sampling inspection that included an
Aquatic Toxicity (AT) test that evaluated the biological effect of the facility's discharge on
test organisms. As part of the inspection a tour of the Wastewater Treatment Plant was
conducted. All requirements, observations, and a suggestion are in the Part D Summary of
Findings/Comments section of this inspection report. On February 15 and February 17,
Whole Effluent Toxicity samples were collected from DuPont's Outfall 002 24-hour
composite sample for use in a chronic Ceriodaphnia dubia pass/fail toxicity test. These
aquatic toxicity samples were divided by the "true split" sample splitting method and were
sent to two Whole Effluent Toxicity testing laboratories. One split sample was sent to your
commercial laboratory (Meritech), and the other split sample was sent to the Division of
Water Quality Aquatic Toxicity Laboratory, (located on Reedy Creek Road in Raleigh).
The results of both laboratories were in agreement: the Whole Effluent Toxicity (at a dilution
of. 3.3%) resulted in a "PASS". Test results for these samples indicated that the effluent
would not be predicted to have water quality impacts on receiving water. The same effluent
24-hour composite sample that was collected by DuPont at the Outfall 002 on February 15
was also analyzed for the following parameters (which are currently in your NPDES Permit):
Biochemical Oxygen Demand (BOD), Ammonia Nitrogen, Total Phosphorus, and Total
Nitrogen (NO2 + NO3 + TKN). These chemistry analyses were sent to the Division of
Water Quality Chemistry Laboratory (located on Reedy Creek Road in Raleigh), and the
results of these parameters were as follows: Biochemical Oxygen Demand = <2 mg/L, NH3
as N — 0.02 mg/L, Total Kjeldahl N = 0.62 mg/L, NO2 + NO3 = 0.92 mg/L, and Phosphorus
= 0.67 mg/L.
225 Green St., Suite 714, Fayetteville, NC 28301-5043
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 One
Internet: www.ncwaterquallt t.org NOrffi Cdrol.ui a
An Equal Opportunity \ Affirmative Action Employer
ALztlmally

Mr. Johnson
March 22, 2011
Page 2
As according to the enclosed March 4, 2011 email from Jamie Lewis (ORC), the
corrective actions to the following opportunities for improvement that were noticed during
the inspection have already been implemented:
1) The 002 flow meter (influent river water) was calibrated at a frequency of
approximately once every three years. The requirement is once per year.
2) The operator worksheet did not indicate the Outfall identity as 001 for flow meter
totalizer readings; but, the worksheet did indicate that it was the flow readings at
the "Flume". It was understood as being the designated 001 Outfall point.
3) At 6 AM, the Outfall 001 totalizer flow meter readings were recorded on the
operator worksheet (the written integrator number). The 24-hour composite
sample was routinely taken off at 8 AM. It would be best to performed both at the
same time so that the 24-hour composite sample would accurately represent the
exact same 24-hour flow period.
4) The MGD flow readings that were used for the pounds per day calculations were
usually taken from the operator worksheets that he wrote as the integrator number
at 6 AM.while he was at the Outfall 001 site location. But occasionally, the MGD
totalizer flow was also taken from a different electronic flow meter reading
location for use in the pounds calculation on the DMR, which may also have been
at a time other than 6 AM, and may not have been the same number that was
recorded at 6 AM.
During the week of this inspection, the facility was found to be in compliance with
permit NC0003573. In the future, please indicate on the DMRs that the Influent flow meter
was used to estimate the flow at Outfall 002, instead of an Effluent flow measuring device as
was previously noted. You are commended your continued success with the wastewater
treatment plant. I appreciate the time and professional courtesy that was extended by your
staff during the inspection. Jamie Lewis's cooperation and attitude for improvement was
greatly appreciated. If you have any questions about this report, please contact me at (910)
433-3312.
Dale Lopez
Environmental
Enclosures:. EPA Water Compliance Inspection Report
and Facility Site Review (checklist)
Regional Field Inspectors Check List for Field Parameters
Water Balance (Revised 12/07/06) flow diagram
cc: Jamie Lewis, ORC
FRO Files (Mark Brantley)
Danny Strickland, DWQ-FRO

United States Environmental Protection Agency
EPA Washington, D.C. 20460 Form Approved.
OMB No, 2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2 151 31 NC0003573 111 121 11/02/15 117 181B 191S 201 1
Remarks 21111111111111111111111IIIIII1111111111111111111Inc
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---- -- ------Reserved--------------
671 4.0 169 701 31 71 11 721 N I 73Ir_I 174 71[__l 1 1 1 1 Li 80
Section B: Facility Data _u
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Dupont Fayetteville Works
09:00 AM 11/02/15 07/07/01
22828 NC Highway 87 West Exit Time/Date Permit Expiration Date
Fayetteville NC 283067332 02:00 PM 11/02/15 11/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
Jamie Ray Lewis/ORC/910-678-1143/
Name, Address of Responsible OfficiallTitle/Phone and Fax Number
Michael Johnson,22828 NC Highway 87 West Fayetteville NC Contacted
283067332//910-678-1155/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement 0 Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal 0 Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and n e(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date .
Dale Lopez FRO WQ//910-433-3300 Ext.712/ ell
Signature of anagement Q A eviewer Agency/Office/Phone and Fax Numbers Dae
3
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page #

NPDES yr/mo/day Inspection Type
3I NC0003573 I11 12I 11/02/15 X17 18IBI
(cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed you will find a copy of the Compliance Biomonitoring Inspection report for the inspection that
Danny Strickland (DWQ-Fayetteville Regional Office) and I conducted on February 15 and 17, 2011. The
inspection included the same objectives as that of a routine Compliance Evaluation Inspection plus a
sampling inspection that included an Aquatic Toxicity (AT) test that evaluated the biological effect of the
facility's discharge on test organisms. As part of the inspection a tour of the Wastewater Treatment Plant
was conducted. All observations and recommendations are in the Part D Summary of Findings/Comments
section of this inspection report. On February 15 and February 17, Whole Effluent Toxicity samples were
collected from DuPont's Outfall 002 24-hour composite sample compositer for use in a chronic
Ceriodaphnia dubia pass/fail toxicity test, These aquatic toxicity samples were divided by the "true split"
sample splitting method and were sent to two Whole Effluent Toxicity testing laboratories. One split sample
to your commercial laboratory (Meritech) and the other split sample was sent to the Division of Water
Quality Aquatic Toxicity Laboratory, (located on Reedy Creek Road in Raleigh). The results of both
laboratories were in agreement: the Whole Effluent Toxicity (at a dilution of 3.3%) resulted in a "PASS".
Test results for these samples indicated that the effluent would not be predicted to have water quality
impacts on receiving water. The same effluent 24-hour composite sample that was collected by DuPont at
the Outfall 002 on February 15 was also analyzed for the following parameters (which are currently in your
NPDES Permit): Biochemical Oxygen Demand (BOD), Ammonia Nitrogen, Total Phosphorus, and Total
Nitrogen (NO2 + NO3 + TKN). These chemistry analyses were sent to the Division of Water Quality
Chemistry Laboratory (located on Reedy Creek Road in Raleigh), and the results of these parameters were
as follows: Biochemical Oxygen Demand = <2 mg/L, NH3 as N = 0.02 mg/L, Total Kjeldahl N = 0.62 mg/L,
NO2 + NO3 = 0.92 mg/L, and Phosphorus = 0.67 mg/L.
The following items were addressed and the corrective actions have already been implemented. For the
corrective actions, please see the enclosed March 4, 2011 email from Jamie Lewis, ORC. During the
inspection, I noted the following: 1)The 002 flow meter (influent river water) was calibrated at a frequency of
approximately once every three years.2)The operator worksheet did not indicate the Outfall identity as 001
for flow meter totalizer readings; but, the worksheet did indicate that it was the flow readings at the "Flume"
(and therefore, that it was the 001 Ouffall).3)At 6 AM, the Outfall 001 totalizer flow meter readings were
recorded on the operator worksheet (the written integrator number). The 24-hour composite sample was
routinely taken off at 8 AM. Both should be performed at the same time so that the 24-hour sample would
accurately represent the exact 24-hour flow period. 4)The MGD flow readings that were used for the pounds
per day calculations were usually taken from the operator worksheets that were read at 6 AM at the Outfall
001 site location. But occasionally, the MGD totalizer flow was taken from an electronic flow meter reading
at a time other than 6 AM, thus possibly causing disagreement between the two 24-hour flow meter
readings that may have been recorded for same 24-hour period by two different individuals. It would be
better that the two 24-hour flow meter readings agreed exactly when calculating pounds per day for the
DMRs.
Requirements: 1) Already implemented (see #1 above),2)Already implemented (see #2 above), 3)Already
implemented (see #3 above), 4)Already implemented (see #4 above), 5)Beginning with the most recent
DMR to be submitted, please note on the Outfall 002 DMR that the Influent flow meter was the measuring
device for Outfall 002 (please see the Flow column on the DMRs).Suggestion: 1)During the inspection, rust
was noticed on the catwalk of one of the clarifiers. It is suggested that painting the catwalk may be helpful
in preventing repairs due to corrosion in the future. During the week of this inspection, the facility was
found to be in compliance with permit NC0003573. You are commended for the continued success of the
wastewater treatment plant. I appreciate the time and professional courtesy that was extended by your staff
during the inspection; Jamie Lewis's cooperation was greatly appreciated. If you have any questions about
this report, please contact me at [phone].
A Brief Description of DuPont — Fayetteville Works WWTP: The Polyvinyl Fluoride (PVF) facility began
Page # 2

Permit: NC0003573
Inspection Date: 02/15/2011
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
production in October 2007, and an expansion of that product started up in June 2010. SentryGlas® (SG),
located on the North side of plant, ButaciteO (West side), NafionO (East side) merged influent process and
domestic flows (from the Sanitary Sewage Lift Station at Third Street and C Street) in the Collection Sump
from two lines. The PPA Process (processing aid for Teflon@) wastewater was shipped out, except for the
sanitary sewer. The influent had between 500 to 700 mg/L of BOD (90% of the BOD & COD came from the
Butacite@ Plant) and between 1000 to 2,000 mg/L of COD. Flow could be diverted (by automatic
switch -over) to a 175,000 -gallon capacity Retention Tank (that handled spills and chemical slugs), and later
sent back to the Collection Sump through a two-inch line. Normally, the flow was pumped to an 850,000
gallon capacity Equalization Basin (EQ), which had three aerators (40 HP each) and two mixers (20 HP
each). In the EQ basin, there was re -circulation through a Muffin Monster; the flow then went back to the
EQ basin. The Collection Sump and the Equalization Basin were considered as the Primary Treatment
Units, The Pre -Digester Tank, Aeration Tank (20 feet deep, with 3 feet of freeboard), and the two Clarifier
Tanks were considered as the Secondary Treatment Units. Flow was then pumped to an aerated
Pre -Digester Tank, with a 50 horsepower (HP) aerator and a 15 HP blower. Adsorption of the
hydrocarbons onto the bacteria occurred in the Pre -Digester Tank. Flow was then pumped to an Aeration
Tank (where Absorption occurred), diffused air by two blowers (each rated at 4,000 cubic feet per minute
(CFM), one blower rated at 11200 CFM, and two BioMixers). Ammonium hydroxide (28% concentration)
was used as a nitrogen nutrient source, and phosphoric acid was used for the phosphate nutrient source.
Both were continuously added to the Aeration Tank. In addition, when the production plant was down and
the biomass food source was low, sodium acetate or Mt. Olive pickle brine was added to the Aeration Tank
as a carbon source to keep the biomass in good condition. Folic acid was continuously added as a
micronutrient. Flow traveled to the two circular Clarifier Tanks. #1 Clarifier Tank was 454eet in diameter and
10 -feet deep. #2 Clarifier Tank was 554eet in diameter and 10 -feet deep. An Authorization to Construct (A
to C) is presently in the process for a #3 Clarifier Tank. For process control, the sludge blanket has a target
range of between zero to 5 feet was maintained in each Clarifier Tank, The Return Activated Sludge (RAS)
was pumped from the two circular Clarifier Tanks to the Aeration Tank. Scum that was collected from the
Clarifier Tanks was pumped to the Equalization Basin. Effluent from the Clarifier Tanks flowed to a 64ch
Parshall Flume, The Outfall 001 composite sampler was located at the Parshall Flume, Outfall 001 effluent
had treated wastewaters from the Sanitary Wastewater, Demineralizer Regeneration Wastewater, Process
Wastewater from the Butacite Plant Area, Process Wastewater from Nafion Area, and process wastewater
from Sentry Glass Plus. Flow from Outfall 001 traveled into a board lined ditch, which contained the boiler
blow -down from Dupont oilfired boilers, boiler blow -down, the once -through cooling water, and filter
backwash that was discharged to the Nafion@ ditch, which then flowed to a wood- lined ditch. Approximately
50 to 100 feet downstream of where Outfall 001 flow commingled with flow that was in the Board Lined
Ditch; the flow then passed under a board deck that supported the Outfall 002 compositor. For compliance
monitoring of samples for chronic toxicity and according to the NPDES permit, the samples were taken
downstream of the confluence of outfall 001 and 002. An A to C is in the process for the relocation of Outfall
002 to the Cape Fear River at a location upstream of Lock and Dam No. 3. Waste Activated Sludge (WAS)
flowed from the underfloor of the two Clarifier Tanks and traveled to the Dissolved Air Floatation (DAF)
Tank. The solids were pumped to a Holding Tank, then to a Feed Tank (with coagulant). The flow was
thickened (with polymer addition) in the Pre -Thickener Tank (Steam addition). Solids were dewatered in the
Screw Press (with Steam addition); and, the Total Solids analysis at this point ranged from 9% to 18%. A
conveyor transferred the solids to a Hold -Up Tank, where it was mixed with lime. Solids traveled along
another conveyor, then through an air and steam dryer (the air going to an Odor Scrubber and vented to the
atmosphere). The dried solids were transferred onto another conveyor, to a Sludge Waste Container, and
finally to the Sampson County (Roseboro) Landfill (Waste Industries, Inc.), a commercial Subtitle D landfill.
The final day filter sludge Total Solids analysis ranged from 35 to 60%.
SUMMARY OF INDUSTRIES: Nafion@ Manufacturing: Nafion@ Membrane is a plastic film used in the
chloroalkali industry and in electro chemical fuel cells. Nafion@ Resins are ultimately extruded into a
Page # 3

Permit: NC0003573
Inspection Date: 02/15/2011
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
finished film. The FLPR Vinyl Ether and HFPO monomers are shipped to other DuPont locations to produce
various fluorochemical products such as DuPont Teflon®. Wastewater from this facility is discharged to the
WWTP.
(Teflon® is no longer at this site.)
Butacite® Manufacturing: Produces Butacite® Interlayer plastic sheeting used in safety glass. Polyvinyl
butyral (PVB) resin is shipped off-site as a transfer to other DuPont locations for final processing. The
wastewater from this manufacturing facility is treated in the site's biological WWTP.
SentryGlas® Manufacturing: This is an Tonoplast interlayer laminate used for production of laminated
automotive safety glass and architectural safety glass. This manufacturing process started in June 2005.
No process wastewaters flow to the WWTP. Non -contact cooling water is discharged the wood lined ditch
and ultimately to the Outfall 002,
Polymer Processing Aid (PPA) Manufacturing: Fluorocarbon compounds are produced and shipped to
other DuPont facilities where they are used as processing aids in the production of fluoropolymers and
fluorinated telomers. The wastewaters that are generated in this process are collected and shipped off-site
for disposal.
Polyvinyl Fluoride resins (PVF) Manufacturing: This facility produced PVF and began production in October
2007 with an expansion that started up in June 2010. PVF is used in DuPont TedlarO 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 was treated at the on-site wastewater treatment plant. Wastewater from the PVF process contained
un -reacted vinyl fluoride, with little or no BOD value. The expected concentration of vinyl fluoride at Outfall
0002 was 0.0035 mg/L. Non -contact cooling water, condensate, and storm water was discharged to Outfall
002.
Additional notes from the DuPont site visit on 02-15-2011: All units were up. DuPont has been hauling
sludge at a rate of one truckload per day because the sludge heat dryer, located in the filter press building,
has been down for approximately six weeks. Plans were to start back next week. There were two manholes
that were approximately %2 mile upstream of the influent collection sump. The manholes had pH adjustment
with 20% sodium hydroxide (caustic soda) with a pH meter and automatic pressure header to adjust to 9.5
pH units. The Butacite plant added phosphoric acid to the WWTP influent wastewater. The WWTP also had
the ability to add phosphoric acid if needed. In the aeration tank 28% aqueous ammonium hydroxide was
added, Folic acid was continuous added to the Return Activated Sludge (RAS) that was going back into the
aeration basin. There were three blowers in the aeration basin: one 1500 cfm, and two 4,000 cfm. There
were two aerators in the EQ Basin. The new Clarifier (#3) may go into service at the end of March 2011.
Plans were to put a new Clarifier (#3) on line, take #1 & #2 clarifiers off-line for repair. #1 & #2 will be kept
operational, but not in service. Neither chlorine nor any other disinfectant was added; this WWTP was not
required to test for fecal coliform because this industry was less than 2% domestic and fecal coliform would
probably not survive in such a harsh chemical environment. The 001 Parshall Flume was calibrated on
August 16, 2010 and more recently February 1, 2011 by Richard Brown with ISI Instrumentation Services,
Inc, no adjustment was needed for either calibration. The 002 flow measuring device was a Rosemont 1151
DP (Differential Pressure) Flowmeter (venturi type) located at the DuPont facility's Cape Fear water intake
(a 42 -inch pipe). Possible sources of flow error when using influent flow values for the estimated effluent
flow from the facility to the River: effect of evaporation loss within the entire DuPont facility, effect of
infiltration, use of purchased potable water that flowed thru the WWTP, and the influence of the storm water
volume from a rain event. The 002 flow meter totalizer readings were recorded on the operator's worksheet.
Although the A to C has been approved (ATC #003573A02), the clearing and construction projects have not
Page # 4

Permit: NC0003573
Inspection Date: 02/15/2011
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
begun yet. According to Mike Johnson, plans are to also have an effluent flow meter with the relocation of
Outfall 002.
Page # 5

Permit: NC0003573
Inspection Date: 02/15/2011
Operations &Maintenance
Is the plant generally clean with acceptable housekeeping?
Owner - Facility: Dupont Fayetteville Works.
Inspection Type: Bioassay Compliance
Yes No NA NE
■nnn
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n
Judge, and other that are applicable?
Comment:
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
Is the facility as described in the permit?
#Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DM Rs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual perf
orming the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitt
ed its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitt
ed flow) Do they operate 24/7 with a certified operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Yes No NA NE
■non
■nnn
■nnn
■nnn
■nnn
Yes No NA NE
■nnn
■nnn
■nnn
■nnn
■non
■
■
■
■
■
■
■nnn
■nnn
■nnn
■nnn
■nnn
■nnn
■nnn

Permit: NC0003573
Inspection Date: 02/15/2011
Record Keepin
Facility has copy of previous year's Annual Report on file for review?
Comment:
Effluent Pipe
Is right of way to the outfall properly maintained?
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Flow Measurement -Influent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: The influent flow reading at the intake from the Cape Fear River (for the
whole production plant) was used for the 002 Effluent flow reading on the DMR.
Starting with the most recent DMR, please indicate that the Influent flow measuring
device was used for estimating the Outfall 002 flow. This flow meter was calibrated on
a frequency of approximately once every three years. Immediately after this inspection,
DuPont implemented an Influent flow meter calibration schedule of once per year.
Flow Measurement -Effluent
# Is flowmeter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
If
units are separated} Does the chart recorder match the flow meter?
Comment: The Outfall 001 was correctly report
ed as an Effluent Flow measuring
device in the column on the DMR for Flow (code 50050).
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
Yes No NA NE
❑ ■ ❑
Yes No NA NE
■nnn
■.nnn
Yes No NA NE
■nen
n■nn
■nnn
nnn■
Yes No NA NE
■nnn
■nnn
■nnn
■nnn
Yes No NA NE
■nnn
■nn❑
■nn❑
■nnn
■Inn
Page # 7

Permit: NC0003573
Inspection Date: 02/15/2011
Solids Handling Equipment
The facility has an approved sludge management plan?
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
Comment: DuPont has been hauling sludge at a rate of one truckload per day
because the sludge heat dryer, located in the filter press building, has been down for
approximately six weeks. Plans were to start back next week.
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Comment:
Yes No NA NE
Yes No NA NE
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? ■ ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier? ■ ❑ ❑ ❑
Are weirs level? ■ ❑ ❑ ❑
Is the site free of weir blockage? ■ ❑ ❑ ❑
Is the site free of evidence of short-circuiting?
Is scum removal adequate? ■ ❑ ❑ ❑
Is the site free of excessive floating sludge? ■ ❑ ❑ ❑
Is the drive unit operational? moon
Is the return rate acceptable (low turbulence)? ■ ❑ ❑ ❑
Is the overflow clear of excessive solids/pin
floc? ■ ❑ ❑ ❑
Is the sludge blanket level acceptable( (Approximately
'/< of the sidewall depth) ■ ❑ ❑ ❑
Comment: During the inspection, rust was noticed on the catwalk of one of the
clarifiers. It is suggested that painting the catwalk may be helpful in preventing repairs
due to corrosion U future. The new Clarifier (#3)may go into service at the end of
March 2011. Plans were to put the new Clarifier (#3) in service, and take #1 & #2
clarifiers off-line for repair. It is planned that #1 & #2 will be kept operational, but not in
service.

Permit: NC0003573
Inspection Date: 02/15/2011
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/I)
Comment:
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
Yes No NA NE
Ext. Air
Diffused
■nnn
■nnn
■nnn
■nnn
■❑❑n
■nnn
■nnn
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? moon
Are all other parameters(excluding field parameters) performed by a certified lab? ■ ❑ ❑ ❑
# Is the facility using a contract lab? ■ n ❑ n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ n ❑ n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ■ n
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? n n ■ n
Comment:
Effluent Samplin Yes No NA NE
Is composite sampling flow proportional? ■ o o ❑
Is sample collected below all treatment units? ■ n n n
Is proper volume collected? ■ n n n
Is the tubing clean?
■nnn
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ n n ❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ Q ❑ ❑
Comment:
Page # 9

Regional Field Inspectors Check List for Field Parameters
Name of site to be Inspected: DuPont
Date: uz-] 5 -
Field certification IF (if applicable): 5105 Inspector: DajEQ
NPDES #: NC 0003573 Region: FRO
I. Circle the parameter or parameters performed at this site.
Residual Chlorine, Settleable Solids, I CUH UU V Y,L1e111Ht4,1dLuryj
II. Instrumentation:
A. Does the facility have the equipment necessary to analyze field parameters as circled above?
1. A pH meter Fisher Accumet 50 H Mete es No
2. A Residual Chlorine meter Yes No
3. DO meter Yes No
4. A Cone for settleable solids Yes No
5. A thermometer or meter that measures temperature. es No
6. Conductivity meter Yes No
III. Calibration/Analysis:
1. Is the pH meter calibrated with 2 buffers and
checked with a third buffer each day of use? LY es No
2. For Total Residual Chlorine, is a check standard
analyzed each day of use? Yes No
3. Is the air calibration of the DO meter performed
each day of use? Yes No
4. For Settleable Solids, is 1 liter of sample
settled for 1 hour? Yes No
5. Is the temperature measuring device calibrated
annually against a certified thermometer? es No
Janua 2010
6. For Conductivity, is a calibration standard
analyzed each day of use? Yes No

IV. Documentation:
I Is the date and time that the sample was collected documented? es No
2. Is the sample site documented? es No
3. Is the sample collector documented? es No
4. Is the analysis date and time documented? L es No
5. Did the analyst sign the documentation? 1yesi No
6. Is record of calibration documented? es No
7. For Settleable Solids is sample volume and
1 hour time settling time documented? Yes No
8. For Temperature, is the annual calibration of
the measuring device documented? es No
Janua 2010
Comments:
pH 4 Buffer expiration date was 07/31/2013
pH 7 Buffer expiration date was 09/30/2013
pH 10 Buffer expiration date was 07/31/2013
Please submit a copy of this completed form to the Laboratory Certification Program.
DWQ Lab Certification
Chemistry Lab
Courier # 52-01-01
FIELD INSPECTOR CHECKLIST REV, 04/23/2002

Dale
From:
Sent:
To.
Subject,
Attachments:
Hey Dale,
Jamie R Lewis [[e-mail]
Friday, March 04, 2011 12:48 PM
Lopez, Dale
Re: FW: DuPont CEI and WET sampling (BIO inspection) on February 8th and 10th
Brief Description of DuPont.doc
I just wanted to give you an update on the items we found during our audit.
1 - We have updated our calibration on our 002 flow meter to a 1 year calibration.
2 -Changed wording on our daily report to say "001 integrator reading @ 0800"
3 -Updated our integrator reading from 0600 to 0800 to match our sample removal.
4 -Changed our electronic shift notes format to match our written integrator number.
Thanks,
Jamie
"Lopez, Dale" <dale.lopez(7a ncdenr.gov>
01/05/2011 12:18 PM
Hi Jamie,
To Jamie RLewis/AE/DuPont@DuPont
cc "Lopez, Dale" <dale.looez(o�ncdenr.gov>, Danny Strickland
<[e-mail]>
Subject FW: DuPont CEI and WET sampling (BIO inspection) on February 8th and 10th
As per your request yesterday, the inspection will be during the week of February 14`h instead of February 7th. Danny
Strickland and I will arrive at the truck entrance gate at 9:00 AM on February 15`h and on February 17`h at 9 AM for the split
procedure with you (Meritech). If there is enough sample after you take your chemistries, I would like to collect some of the 24-
hour composite for BOD, COD, T -Phos, and T -Nitrogen (for an additional amount of <2 liters),
Thanks,
Dale
From; Lopez, Dale
Sent: Thursday, December 30, 2010 11:28 AM
To: jam ie. r. [e-mail]
Cc: Lopez, Dale; Danny Strickland
Subject: DuPont CEI and WET sampling (BIO inspection) on February 8th and 10th
Hi Jamie,
As per our phone conversation this morning, Danny Strickland and I will be visiting your WWTP for a routine BIO inspection
(CEI &WET Sampling) on Tuesday, February 8th , (arriving at the truck entrance gate at 9:00 AM) and on Thursday, February 10tH
,(9:00 AM at the gate). I understood that you would start your 15` WET sample at 9 AM on Monday February 7th , and that I would
be permitted to obtain a "split' sample; the same start time with your 2nd sample. In order to perform the "True Split Procedure", I
will need to be present at the time that each of the 24-hour composites is poured into the WET cubitainers (on Tuesday and
Thursday), that I estimate will be 9:30 AM on both days. Thank you for collecting enough volume of sample from your 24-hour
composite equipment for me to split samples.
rit