HomeMy WebLinkAbout3. 2011 renewal applicationaU PONT,
Mrs. Dina Sprinkle
NCDENR Division of Water Quality
Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
SUBJECT: NPDES Permit Renewal Apllication
NPDES Permit No. NC0003573
Dear Mrs. Sprinkle:
DuPont Fluoroproducts
Fayetteville Warks Plant
22828 NC Highway 87 West
Fayetteville, NC 28306-7332
Apri129, 2011
Pursuant to requirements of the referenced NPDES permit, the DuPont Company —Fayetteville
Works is submitting the NPDES Form 1 and Form 2C (original and two copies) for permit
renewal by the Division of Water Quality.
Included in the permit application is a Supplemental Information document which describes the
Current Operations and Proposed Changes. This site is being considered for a project to
construct and operate a third manufacturing facility that will produce polyvinyl fluoride ("PVF")
polymer resins. Two water balances are included in the application: one without the third PVF
facility and one with the third PVF facility.
The application is being submitted without the testing results for Bis(chloromethyl) ether
(CAS No. 542-88-1) as these results were not available at the time of this submittal. These
absent results are indicated by asterisks (***) on Page V-4 of Form 2C. This data will be
submitted as an addendum when the analytical report is received and inputted into a Form 2C.
Should you have any questions or need additional information, please feel free to call me at
(910) 678-1155.
���� D
M�,Y �'' lDi1
DEt.;s:; �� "r�r2 QUALf`tY
POI�d..�,::;;;riCE 13F:APICH
Enclosures
E.I. du Pont de Nemours and Company
Environmental Manager
�s
i
7
34° 52'
UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
DUART QUADRANGLE STATE OF NORTH CAROLINA
NORTH CAROLINA DEPARTMENT OF NATURAL RESOUP
7.5 MINUTE SERIES (TOPOGRAPHIC) w' AND COMMUNITY DEVELOPMENT
SE14 SAINT PAUIS IS' QUADRANGLE ,�J RATFiC;H N r
47'
DUPONT COMPANY - FAY ETTEVILLE WORKS
LOCATIONS OF INTAKE AND DISCHARGE STRUCTURES
c�kjz�
pp
r
t
n {:rZ�
• (2) Waste
Fluorocarbon
(corrosive,
toxic)
_ r t
r
*.
*
P40
jpl
44
VA AV
cc
6a,
N �l i{46
Form 2C, Part 111 13:
WATER BALANCE WITHOUT PVF -3 PROCESS (Revised 04/29/2011)
DuPont Company = Fayetteville Works
Flows Unit: Gallons per Day
Basis: All Production Manufacturing, using Maximum 30 day average of measured flows
749,000
11---------------
1
3,500,000
1
I
I FILTERED
I WATER
1
I SYSTEM
I
NON -CONTACT
RAW RIVER WATER
COOLING WATER
to/ from each unit
1,100,000
DEMINERALIZED
WATER SYSTEM
17,249,000
I
1
1
1 PURCHASED
1 POTABLE
WATER
I
1
I
I
I
I
STORMWATER
1
I
1
I
1
I
I
I
I
I
1
I
I
I
1
I
1
I
I
I
I
I
I
1 186,000
1
I
1
I
I
I
1
Stormwaler from
Process Areas
46,500
Non -process
Stonnwater
Neutralized
Regenerate
I 8,000 I
Sanitary
Facilities
NaOCI
Filtered Water
Demineralized Water
J:
1
Evaporation
fl
BOILERS
it
NPDES PERMIT APPLICATION
Cape Fear River
1
1100,000 I
10
BUTACITEtRI NAFIONtRI SENTRYGLAStRI POLYVINYL POLYVINYL
POLYVINYLBUTYRAL FLUOROPRODUCT LAMINATE FLUORIDE FLUORIDE
MANUFACTURING MANUFACTURING MANUFACTURING RESIN RESIN
PROCESS PROCESSES PROCESS PROCESS #1 PROCESS #2
I t
682,500 90,000 100,000 65,000 65,000
IF IF IF
1,845,500 e 182,000 35,000 35,000
Evaporation
1
Evaporation
Biosolids Moisture
1,032,000
20,864,500
m � � m OUTFALL
ACTIVATED @ � � �
SLUDGE CLARIFI- OUTFALL � � � � 002
WWrP CATION 001
U U U U
t0 IO `N, c0
C C C C
U U U U
20,000 BIOSCLIDS 908,000 z° z z z°
DEWATER/
4,000 DRY;NG
}
DuPont Company — Fayetteville Works
NPDES Permit No. NC0003573
Supplemental Information
Supplemental Information — Permit Renewal Application — April 29, 2011
Current Site Water Management
Process wastewater and stormwater 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 flowrate of the WWTP is
2.0 MGD, with an actual average flowrate 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
submerged 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 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 from 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.
The biologically treated wastewater is then sent to one of two in -ground clarifiers (119,000
gallons and 168,000 gallons respectively) or an above -ground 679,000 -gallon clarifier; with all
clarifiers being operated in parallel. The clarified treated effluent is discharged to and through
Outfall 001.
The wasted sludge is sent to a Dissolved Air Floatation (DAF) unit, then to a 47,000 gallon
Sludge Storage Tank, and finally to a 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 sludge or dewatered/dried sludge is transported off-site to a commercial
Subtitle D landfill.
Non -contact process cooling water and non -process stormwater are conveyed via surface ditches.
In addition, excess riverwater flow and Outfall 001 effluent are discharged directly to a surface
ditch. The combined, total flow of water from the site is discharged and monitored at Outfall
002. The DMR reported Outfall 002 maximum 30 -day average flow was 20.75 MGD during the
period from 2008 to 2010. Flow variability at Outfall 002 was from 3 to 26 MGD, however, this
monitored flow was the influent of river water pumped into the site, and did not include the
discharge of stormwater or treated sanitary sewage.
DuPont Company — Fayetteville Works
NPDES Permit No. NC0003573
Supplemental Information
Supplemental Information — Permit Renewal Application — April 299 2011
Proposed Changes in Operations
PVF -3 Manufacturing Facy: The DuPont Company —Fayetteville Works is being
considered as the location for a third DuPontTM Polyvinyl Fluoride ("PVF") manufacturing
process ("PVF -3"). 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.
Assuming this new facility is sited at the DuPont Company — Fayetteville Works, construction
would be completed in August 2013 and the unit would begin production in September 2013.
The manufacturing .facility will be located near the existing PVF -1 and PVF -2 manufacturing
processes. This process will produce polyvinyl fluoride ("PVF") resin (CAS No. 24981-14-4).
As with most fluorochemical processes, the main wastewater stream from the PVF -3
manufacturing process would have trace or no biological oxygen demand (BODS) value. The
major pollutant associated with this process wastewater would be solid resin (as Total Suspended
Solids). To treat this wastewater, DuPont intends to pump the majority of the PVF -3 process
wastewater directly to the third clarifier, which would remove the resin solids as part of the
activated sludge removed from the WWTP system. Ultimately the resin solids would be
removed from the system as part of the wasted sludge that is sent off site to a Subpart D landfill.
Approximately 3% of the PVF -3 process wastewater contains a cleaning solution will be sent to
the headworks of the site's WWTP.
The PVF -3 Manufacturing Facility would have a process wastewater stream containing a
cleaning solution or surfactant. This wastewater stream, representing approximately 3% of the
total PVF -3 process wastewater, would be sent to the headworks of the site's WWTP for
biological treatment.
Finally, non -contact cooling, condensate, and stormwater from the PVF -3 Manufacturing
Facility will be discharged directly to Outfa11002 via the site's non -contact water ditch.
DuPont Company — Fayetteville Works
NPDES Permit No. NC0003573
Supplemental Information
Supplemental Information — Permit Renewal Application — April 29, 2011
Current Operating Conditions
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 chloroalkah industry and in electrochemical fuel cells. NafionO 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.
PPA Manufacturing: The DuPont Company —Fayetteville Works' PPA manufacturing
area produces several polymer processing aids. The processing aids produced in this unit are
used to produce fluoropolymers and fluorinated telomers, but none of the produced processing
aids are used at the Fayetteville Works site. This facility was started up in November 2002. All
process 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.
SentryGlas&
Manufacturing: The DuPont Company —Fayetteville Works' SentryGlas®
manufacturing area produces DuPontTM SentryGlas� Tonoplast interlayer laminate. SentryGlas®
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 a surface ditch and ultimately to Outfall 002.
PVF Manufacturing: The DuPont Company —Fayetteville Works' PVF manufacturi
ng
area produces polyvinyl fluoride resin is used in the electronics industry as a backing for
photovoltaic cells, as well as many other uses. The PVF4 facility was constructed in 2006-2007
and was started up in September 2007. The PVF -2 facility was constructed in 200&2010 and
was started up in June 2010. Process wastewater generated from this manufacturing facility is
treated in the WWTP.
DuPont Company — Fayetteville Works
NPDES Permit No. NC0003573
Supplemental Information
Supplemental Information — Permit Renewal Application — April 29, 2011
Form 2C Permit Application
Data Unavailable
The Outfall 001 and Outfa11002 analytical results for Bis(chloromethyl) ether were not available
at the time of this permit renewal application submittal. These absent analytical results are
indicated with asterisks (***) on Page V-4 of Form 2C. This data will be submitted as an
addendum when the analytical report is received.
DuPont Company — Fayetteville Works
NPDES Permit No. NC0003573
Supplemental Information
Supplemental Information — Permit Renewal Application — April 29, 2011
Sludge Management Plan
The DuPont -Fayetteville Works operates a Class 3 Wastewater Treatment Plant which is
comprised of a single -stage activated sludge biological system.
Excess sludge is removed from the system by 1:7'r rt f thRlvated Sludge (at
approximately 0.6% solids) from the clarifiers to a Dissolved Air Floatation ("DAF") unit for
initial thickening.
The sludge from the DAF (at approximately 3% solids) is transferred to a Mix Tank where
polymer agents are added to enhance the dewatering process.
The semi -thickened sludge is transferred from the Mix Tank to a Rotary Filter for final
thickening, whereby the sludge is thickened to 6% solids.
The thickened sludge is then transferred to a Screw Press where itis dewatered to a concentration
of 9-20% solids.
Following the Screw Press, the sludge is typically dried in steam heated dryers to a concentration
of 40-55% solids.
On the average, the weekly quantity of generated dried sludge is approximately 23,000 lb.
The dri
ed sludge, or on occasion the dewatered 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.
DuPont Company - Fayetteville Works
NPDES Permit NC0003573
Total Volume of the Water Handling System Between Entry of Biocidal Product and NP ES
Discharge Point
Wastewater Treatment
Plant Unit
Volume
milliongallons)
Equalization Basin
0.850
Pre -Digester Tank
0.250
Aeration Tank
1.700
#3 Clarifier 0.679
TOTAL 3.479
Flow Diagram from Entry Point of Biocidal Product (PVF -3 Cooling Tower) to the NPDES
Discharge Point (NPDES Outfall 002)
PVF -3
COOLING
TOWER
WASTEWATER
TREATMENT
PLANT
NPDES
OUTFALL
002