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NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
CERTIFIED MAIL: 7007 1490 0004 5533 6738
RETURN RECEIPT REQUESTED
Mr. Ron Hall
Site Manager, Dupont Fayetteville Works
E.I. DuPont de Nemours & Company
4610 Braxton Rd.
Grifton, NC 28530
Division of Water Quality
Charles Wakild, P.E. Dee Freeman
Director Secretary
April 27, 2012
SUBJECT: NOTICE OF VIOLATION: NOV-2012-TX-0027
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NC0003573
Dupont -Fayetteville Works
Bladen County
Dear Mr. Hall:
RECEIVE
MAY 0 4 2012
CERAL FILE_b
DWOBOG
This is to inform you that a review of your toxicity self-monitoring report form for the month of February 2012 indicates a violation of
the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). Your
efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site-specific study designed to identify the causative agents
of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity control options, and confirm reductions in
effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil penalties for violations of
NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DMRs) and Aquatic
Toxicity (AT) Test Forms. We encourage you to review this information; if it would be helpful to discuss this situation or possible
solutions to resolve effluent toxicity noncompliance, please contact Mr. John Giorgino with this office at (919) 743- 8441.
,cerely,
Cindy Moo e
Supervisor, Aquatic Toxicology Unit
cc: Belinda Henson- Fayetteville Regional Office
Dale Lopez- Fayetteville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: 919-743-84001 FAX: 919-743-85171 Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
An Equal Opportunity \ Affirmative Action Employer
NoithCarolina
Naturally
WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information. The items below do not address or include all the toxicity testine and resorting
requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement, please contact Mr.
John Giorgino with the Aquatic Toxicology Unit at (919) 743-8401 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the appropriate
parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT' form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the revortine period
(eg, January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of any
single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit, then at least two multiple
concentration toxicity tests (one per month) will be conducted over the following two months. As many analyses as can be completed will be
accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you
may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement
initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring
requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and December, then toxicity testing must
be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1 -June 30, then you must provide
written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months of the calendar
year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the Environmental Sciences
Section at (919) 743-8401 and provide written documentation indicating why the test was invalidated and the date when follow-up testing will
occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the information block
located at the top of the AT form indicating the facility name, permit number, pipe number, county and the month/year of the subject report.
You should also write "No Flow" on the AT form, sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for facilities which have not
received a facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT form must also be
signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,oy u may consider submitting your toxicity test
results certified mail, return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 NorthCarolina
Phone: 919-743-84001 FAX: 919-743-85171 Customer Service: 1-877-623-6748
Internet: hdp:flh2o.enr.state.nc.us/esb/ Naturally
An Equal Opportunity 1 Affirmative Action Employer