DEQp00021058

Re: Process Change and Permit Implications
' Subject: Re: Process Change and Permit Implications
Date: Tue, 26 Sep 2000 10:41:21 -0400
From: Tom Belnick <[e-mail]>
To: Michael E Johnson <[e-mail]>
Hey Mike- I ran this one by Dave. Our thought is to go ahead and make the pump
change now. It sounds like a process change, so no ATC would be needed. We
can take another look at the additional fluorocarbons during permit renewal.
It doesn't look like they would be limited by either Federal Guidelines or NC
water quality standards. At most we might consider monitoring. Are there any
analytical tests for effluent that covers these compounds, and would effluent
concentrations be expected to increase significantly?
Michael E Johnson wrote:
> Tom,
> As we discussed this morning, the Nafion Process (SIC Code 3083) at the
> DuPont - Fayetteville Works wishes to replace an existing vacuum pump with
> a new liquid -ring vacuum pump to increase the reliability of the pump and
> to reduce maintenance costs.
> This change will result in added load to the site's Wastewater Treatment
> Plant (WWTP) that is regulated under NPDES Permit Number NC0003573.
> V question is what, if anything, is required by DWQ to allow this change
> to take place?
> Currently the existing vacuum pump is used as part of a recycle still to
> pull out fluorocarbon compounds from the desired product. Those compounds
> are currently emitted as air emissions.
> With the new liquid -ring vacuum pump, some of the high boiling fluorocarbon
> compounds will be condensed by the cooler water in the vacuum pump, and
> will be ultimately discharged to the WWTP at a flow rate of 3-5 gpm. These
> are fluorocarbon compounds that are currently being sent to the WWTP, so no
> new chemicals are being introduced to the system. The anticipated increase
> in quantity is 220 lb. per year, or 0.6 lb/day. Virtually none of this
> material will be biodegraded, and will leave the system primarily as water
> discharged to the Cape Fear River, with some smaller losses as air
> emissions from the diffused air system of the WWTP.
> The closest effluent guideline that I can find that might cover this
> manufacturing process is 40 CFR 414.40 (Subpart D - Thermoplastic Resins)
> since this process makes a fluorocarbon resin that is then extruded into a
> film.
> If you need additional information, please contact via response to this
> Email note or call me at 910-678-1155.
> Thanks for your help,
> Mike
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