DEQp00021477

O 'C
June 25, 2008
Karen Wrigley, Plant Manager
Dupont — Fayetteville Works
E.I. DuPont de. Nemours & Company
22828 NC Hwy 87 West
Fayetteville, NC 28306-7332
Subject: Compliance Evaluation Inspection (CEI)
DuPont — Fayetteville Works
NPDES Permit No. NC0.003573
Bladen County
Dear Ms. Wrigley:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins., Director
Division of Water Quality
Enclosed you will find a copy of the Compliance Evaluation Inspection (CEI) report for the
inspection conducted on June 12, 2008. As part of the inspection a tour of the Wastewater
Treatment Plant was conducted. All observations are in Section D. Summary of
Findings/Comments of this inspection report.
You are commended for the continued success of the wastewater treatment plant. We
appreciate the time and professional courtesy that was extended by your staff during the
inspection. If you have any questions or comments concerning this report or require
clarification on part(s) of this report, please feel free to contact me at [phone].
incerely, )
Dale Lopez
Environmental Specialist
Enclosures: Brief Description of DuPont — Fayetteville Works WWTP
EPA Water Compliance Inspection Report
Facility Site Review (checklist)
Regional Field Inspectors Check List for Field Parameters
cc: Marlene Page, Area Superintendent, DuPont — Fayetteville Works
Mike Johnson, Environmental Manager, DuPont — Fayetteville Works
Robert Geddie, ORC, DuPont — Fayetteville Works
FRO Files
Central Files
NoithCarolina
Nalmally
North Carolina Division of Water Quality 225 Green Street - Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us FAX [phone].623-6748
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

Brief Description of DuPont — Fayetteville Works WWTP:
The Polyvinyl Fluoride (PVF) facility was under construction and is expected to go on line
before the end of the year 2007. Sentry Glass Plus (SGP), located on the North side of plant, Butacite
(West side), Nafion (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. Flowing into the
Collection Sump was the process wastewater from PMDF (a Teflon manufacturer located on the East
side of the plant, there were 2 -inch lines for the process flow and the domestic flow). The APFO
(intermediate for Teflon) wastewater was shipped out, except for the sanitary sewer. There was an odor
in the Collection Sump area, probably due to Buta-Aldehyde, and recently, a significant odor from
Nafion of Dimethyl Sulfur Oxide (DMSO). 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 recirculation 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 1,200 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 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 45 -feet in diameter and 10 -feet deep. #2 Clarifier Tank was 55 -
feet 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 6 -inch 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 oil -fired 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 underflow 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 (Stream addition). Solids were dewatered in the Screw Press (with Stream
addition). 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
Roseboro Landfill (Waste Management), 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 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 Manufacturing: Teflon FEP resin is used in the electronics industry as a coating for wire, and
other uses. Wastewater flows to the WWTP.
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.
Sentry Glass Plus Manufacturing: This is an ionoplast 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.
Ammonium Perfluorooctanoate (APFO) Manufacturing: APFO is used to produce fluoropolymers and
fluorinated telomers that are shipped to. other DuPont facilities. 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. PVF is used in DuPont Tedlar 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 Non -contact cooling water, condensate, and storm water was discharged to Outfall 002.

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
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 1 51 31 NC0003573 1 11 121 08/06/12 1 17 18I rel 191 sl 201
+ J
Remarks
211111 11111111 1111 1111111111111111 11111111 11111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ------------------------Reserved---------------------
671 2.0 169 70141 711 1 721 NJ 73 L1J 74 751 1 1 1 1 1 1 1 80
W
Section B: Facility Data
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
10:30 AM 08/06/12
07/07/01
Exit Time/Date
Permit Expiration Date
22828 NC Highway 87 West
Fayetteville NC 283067332
01:30 PM 08/06/12
11/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Robert J Geddie/ORC/910-678-1219/
Name, Address of Responsible Official/Title/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 Flow Measurement Operations & Maintenance 0 Records/Reports
Facility Site Review EffluenttReceiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) an Signatures) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
DC/ale Lopez FRO WQ//910-433-3300 Ext.712/�
Signature of Manageme t Q A eview Agency/Office/Phone and Fax Numbers D to
�
a
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I NC0003573 I11 12I 08/06/12 117 18ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On the day of the Compliance Evaluation Inspection, this complex wastewater treatment facility appeared to
be very well operated and maintained, and continues to maintain a very high standard for wastewater
treatment. Keep up the good work!
Page # 2

Permit: NC0003573
Inspection Date: 06/12/2008
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ D n 0
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ 0 D D
Judge, and other that are applicable?
Comment:
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
n
D
■
D
Is the facility as described in the permit?
■
D
D
D
# Are there any special conditions for the permit?
■
D
D
D
Is access to the plant site restricted to the general public?
■
n
D
n
Is the inspector granted access to all areas for inspection?
■
n
n
n
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
0
n
n
Is all required information readily available, complete and current?
■
D
D
D
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
D
D
D
Are analytical results consistent with data reported on DMRs?
■
n
n
n
Is the chain -of -custody complete?
■
n
D
n
Dates, times and location of sampling
■
Name of individual performing 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?
■
D
D
D
Has the facility submitted its annual compliance report to users and DWQ?
■
n
n
n
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
D
D
■
D
Is the ORC visitation log available and current?
■
D
D
D
Is the ORC certified at grade equal to or higher than the facility classification?
■
D
n
D
Is the backup operator certified at one grade less or greater than the facility classification?
■
D
D
D
Is a copy of the current NPDES permit available on site?
■
D
D
D
Page # 3

Permit: NC0003573
Inspection Date: 06/12/2008
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Facility has copy of previous year's Annual Report on file for review?
■
n
n
n
Comment:
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
■
n
n
n
Are the receiving water free of foam other than trace amounts and other debris?
■
n
n
n
If effluent (diffuser pipes are required) are they operating properly?
■
n
n
n
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
n
n
n
Is flow meter calibrated annually?
■
n
n
n
Is the flow meter operational?
■
n
n
n
(If units are separated) Does the chart recorder match the flow meter?
■
n
n
n
Comment: The flow meter was calibrated twice per year.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
In
n
n
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
n
n
n
Are weirs level?
■
In
n
n
Is the site free of weir blockage?
■
n
n
n
Is the site free of evidence of short-circuiting?
■
n
n
n
Is scum removal adequate?
■
n
n
n
Is the site free of excessive floating sludge?
■
n
n
n
Is the drive unit operational?
■
n
n
n
Is the return rate acceptable (low turbulence)?
■
n
n
n
Is the overflow clear of excessive solids/pin floc?
■
n
n
Cl
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
■
n
n
n
Comment:
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
■
n
n
n
Page # 4

Permit: NC0003573
Inspection Date: 06/12/2008
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Compliance Evaluation
No
NA
NE
Aeration Basins
Yes
No
NA
NE
Are surface aerators and mixers operational?
■
D
n
D
Are the diffusers operational?
■
n
D
n
Is the foam the proper color for the treatment process?
■
D
n
D
Does the foam cover less than 25% of the basin's surface?
■
D
D
D
Is the DO level acceptable?
■
n
n
n
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
n
n
n
Comment: Biomass bioaugmentation with Maryland Biochemical MB8; and, the
microbial food source was supplemented with Sodium Acetate, Folic Acid, Phosphoric
Acid, and Ammonia.
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
n
n
■
n
Is the generator tested by interrupting primary power source?
D
n
■
n
Is the generator tested under load?
n
n
■
n
Was generator tested & operational during the inspection?
D
D
■
D
Do the generator(s) have adequate capacity to operate the entire wastewater site?
D
n
■
n
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
D
D
■
n
Is the generator fuel level monitored?
D
n
■
n
Comment: Both automatic and manual type of switchover. There are two feeder
lines:of electricity: Lumberton Weatherspbon and Duke (Progress Energy).
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
■
n
n
rl
Is the basin free of bypass lines or structures to the natural environment?
■
n
D
n
Is the basin free of excessive grease?
■
D
D
D
Are all pumps present?
■
D
D
D
Are all pumps operable?
■
n
n
n
Are float controls operable?
Cl
0
■
D
Are audible and visual alarms operable?
D
D
D
■
# Is basin size/volume adequate?
■
D
D
D
Comment:
Page # 5

Regional Field Inspectors Check List for Field Parameters
Name of site to be Inspected: DuPont Date: 06/12/08
Field certification # (if applicable): 5105 Inspector?- Dale z
NPDES #: NC 0003573 Region: FRO
I. Circle the parameter or parameters performed at this site.
Residual Chlorine, Settleable Solids, ®H, DO, Conductivity, emper
II. Instrumentation:
A. Does the facility have the equipment necessary to analyze field parameters as circled above?
1. A pH meter Fisher Accumet 5 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? 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? 2/02/0 Fe7s No
6. For Conductivity, is a calibration standard
analyzed each day of use? Yes No

IV. Documentation:
1.
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?
es
No
5.
Did the analyst sign the documentation?
es
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
Comments:
pH 4 Buffer expiration date was February 2010
pH 7 Buffer expiration -date was January 2010
pH 10 Buffer expiration date was January 2010
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

JUL 0
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