DEQp00021366

DuPont Fayetteville Wastewater Permit
Subject: DuPont Fayetteville Wastewater Permit
From: [e-mail]
Date: Thu, 25 Jan 2007 11:32:53 EST
To: [e-mail]
January 24, 2007
Environmental Management Commission/ NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Draft Permit NCO003573
To Whom It May Concern,
I appreciate the opportunity to comment on the renewal of the Discharge Permit for the DuPont Chemical Works in Fayetteville. My
family and I live in Wilmington, NC. My family shares a concern about environmental quality and we feel that government, business,
industry and individual citizens all share a responsibility to protect and improve our environment. We have a heightened concern
about the water quality in the Cape Fear River since the river is the source of our drinking water.
I have several concerns about the draft permit for DuPont. I am especially concerned about potential toxic and carcinogenic
compounds used or produced at the DuPont facility. EPA has identified PFOA, C8 as a likely carcinogen. I have heard that the
Fayetteville plant is the only plant in the United States currently producing C8. Why are there no standards and limits in the permit for
PFOA, C8? Although DuPont states that all the discharge from the PFOA plant is currently treated off site, if C8 is manufactured
on-site there is still the possibility of accidental discharges or changes in operating practices in the future. The discharge permit should
contain a zero discharge limit for C8, so that testing is required and there is regulatory power to act quickly if C8 is detected. In
addition, the ground water standard of 2.0 ppb'for C8 is much too high for a likely carcinogen for which the health risks haven't yet
been completely investigated. The history of C8 contamination of public drinking water in Ohio and West Virginia would seem to make
it imperative that North Carolina use its permit authority to prevent surface or groundwater contamination from occurring here.
I do not understand the rationale for a downstream mixing zone of 4500 feet. I feel that the testing should be conducted at the point
where the discharge enters the Cape Fear River. "End -of -Pipe" testing provides a more accurate picture of the plant's discharges
than allowing a large mixing zone..
Sediment is a major problem in the Cape Fear River that needs to be addressed more intensively from both nonpoint and pant
discharges. The turbidity permit requirements for the DuPont permit should be stricter than in the draft permit. It should be the
responsibility of DuPont to ensure that no sedimentation is being added to the river through their discharge method. The turbidity
requirements of the permit should be tightened.
Finally, the daily max discharge of 7,917 pounds of fluoride seems unnecessarU.y high. Why isn't DuPont recycling or otherwise
removing fluoride from their waste stream? High fluoride levels in drinking water lead to dental problems in humans. There are likely to
be impacts on aquatic animal bones, as well.
I would like to request that the Division of Water Quality schedule a public hearing on the DuPont draft permit to listen to and address
citizens' concerns. Please notify me about a hearing when one is scheduled.
Thank you for the opportunity to comment on this draft permit. I know the Division of Water Quality supports citizen involvement.
Sincerely,
Beth C. Hansen
1116 Shelby Court
Wilmington, NC 28409
[phone]
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