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Home My WebLink AboutDEQp00021677(MP DuPont Fluoroproducts Mr. Paul Rawls NC DENR - Division of Water Quality 225 Green Street - Suite 714 Fayetteville, NC 28301 SUBJECT: Permit Exceedance — November 2002 NPDES Permit No. NCO003573 4 Dear Mr. Rawls: DuPont Fluoroproducts 22828 NC Highway 87 W Fayetteville, NC 28306-7332 January 17, 2003 -During the month of November 2002,' the DuPont- Fayetteville Works exceeded its monthly average BODS permit " limit due to either an excess concentration of a raw material ('plasticizer") in the wastewater influent, or the apparent growth of a polymeric microbial slime in the wastewater treatment plant (WWTP) that resulted from the excess plasticizer- The November waste-water 001 averaged 232.0 lb/day BODS versus the permit limit of 191.3 lb/day BODS. The daily maximum BODS limit was never exceeded during this time_ This incident marked the first time in the site's thirty-year history whereby a permitted monthly average limit was acknowledged as having been exceeded. While it has been the Division of Water Quality's policy to impose a civil penalty for a violation of a monthly average permit limit, the DuPont - Fayetteville Works site asks that the Division consider DuPont's longstanding excellent compliance history and NCDENR's Principles of Enforcement, and waive any civil penalty in this case. The Department's Principles of Enforcement, dated March 31, 2000, outlines the tenets of ensuring environmental regulatory compliance in North Carolina. The Principles state that "in the real world, stewardship is sometimes compromised by conflicting capabilities, priorities, values, and perspectives. This creates the need for regulation and enforcement." In the numeration of twelve enforcement principles, the third principle reads: "Enforcement will be an effective deterrent against future violations." DuPont is in complete agreement with these statements, With the DuPont — Fayetteville Works, however, one sees',a"reguiated. facility with a previously unblemished compliance record and 'a longstanding partnership with'the various divisions of the Department, including the Division of Water Quality. This compliance record and partnership speaks well of DuPont's "capabilities, priorities, values, and perspectives" with regard to environmental stewardship. One can argue that such a regulated entity would not need E.1. du Pura da Nemnuri and Lmmnanv 919-d 900/Zoo'd UN -HUJ HdIZ:ZI soon—I1-80 go ..E ..qy* ..moo "Y:jA ..�?Yz "Sj} i ..�1 ..991 .. S�Ye..h............................ p........ ... x CENTPAL FIL'_=^ Mr. Paul Rawls NCDENR Division of Water Quality January 17, 2003 Page 2 of 3 any "effective deterrent against future violations", and that a single monthly average exceedance of its NPDES permit, after decades of continuous compliance, would not suggest a change in the established and recognized compliance goals and expectations of that facility. BACKGROUND OF PERMIT EXCEEDANCE Staning in January 2002, the ButaciteO manufacturing area began using a new plasticizer in the production of the ButaciteO Polyvinyl Butyral Interlayer sheeting_ This new plasticizer was used without issue for most of 2002. In October 2002, following the site's annual shutdown, WWTP personnel noticed an unusual odor coming from the treatment plant. During the last week of October, WWTP personnel observed a slime coating on several of the major units in the plant. At the same time, COD results from WWTP process control samples were approximately twice higher than normal, however the BODS results for Outfall 001 remained within the normal range throughout October. During the first part of November 2002, the unusual odor and observed slime continued in the WWTP. The site's ORC responded by increasing the MISS of the Aeration Tank in an attempt to improve the biological performance of the WWTP. This action did seem to stabilize the COD discharge and also improved the overall appearance of the system. On November 20, 2002, prior to receiving the BODS analytical results for the week of November 11, 2002, the WWTP personnel called an emergency meeting with the manufacturing areas to determine the source of the slime, which was the suspected cause of the high COD discharge. During that meeting, it was discovered that the Butacite® manufacturing area was experiencing both a similar odor and a similar slime in their process equipment containing the new plasticizer. ButaciteO immediately switched back to the original pre -2002 plasticizer. Following the November 20'h meeting, the site received the Outfall 001 BODS results for the week of November 11, 2002, which were approximately three times higher than normal. During the following week, the discharge at Outfall 001 visibly worsened, so WWTP personnel isolated the Equalization Basin, which contained a wastewater with a large amount of the slime, in hopes that further introduction of the slime into the WWTP would be minimized. The ORC also added freeze-dried commercial bacteria to the system in hopes that the microbes would degrade the slime and/or consume the excess BODS exiting the WWTP. Once the source of the polymeric slime was eliminated, and with the Equalization Basin isolated from the rest of the WWTP system, the slime was eventually purged from the WWTP facility and the plant quickly returned to normal. Since November, the Outfall 00.1 BODS has remained in its normally low range (see attached table). 918-1 900/800*d 61Z-1 AM NOMt 8001-11-80 e " i " q. ..h.G .._.E ..,r.Z ..} .............. ......p. _ ...... ., CENTRAL FOES Mr. Paul Rawls Page 3 of 3 NCDENR Division of Water Quality January 17, 2003 CONCLUSION While the investigation and research continues on this incident, currently it is believed that a change in the Butacitet polyvinyl butyral process occurred that resulted in a decrease of the absorption characteristic of the plasticizer. Tbis, in turn, resulted in a higher quantity of the plasticizer being discharge from the Butacite® area to the site's WWTP. It is speculated that there is a threshold concentration of the plasticizer in the WWTP wastewater at which point the plasticizer and/or the ensuing polymeric slime coats or encapsulates enough of the WWTP microbes so as to render them unable to absorb and degrade the wastewater's organic material. When this occurred in November 2002, non -degraded organics exited Outfall 001 and were analyzed as BOD$. DuPont engineers and scientists are currently working on this problem. The Butacite® manufacturing area has subsequently switched back to the new plasticizer and the WWTP is being carefully monitored for signs of decreased performance. To date no adverse effect has been seen at the WWTP, and the Outfall 001 BODS discharge ren sins at the usual low levels (see the attached table). The WWTP personnel are currently slowly working off the slime -laden wastewater in the isolated Equalization Basin. To remediate the basin, polymers have been added to settle the polymeric slime, which is then removed directly to the sludge handling facility. The supernate from that operation is being sent to the front-end of the WWTP for treatment. The collected slime is being sent off-site for disposal as part of the dewatered biosludge. We appreciate your consideration of the aforementioned request for enforcement clemency. If you should have any questions, please feel free to call me at 678-1155. Michael E. Johnson Environmental Manager cc: Ms. Belinda Henson, NCDENR-DWQ, PRO 928-4 900/tOO'd OIZ-2 41WO . HdBZ:ZI EOOZ-II-adV ) ..® ..q.o ..S�Y/ ..qqu ..fit ..Wfl —SjYZ ..S�y. "W' ..:V:VO ..h. _.. .. .............. _ .q. �..1�. fl h ..W0!..Wal..W&" yy ,,..yy2"..yyt"INWig _'7#INWn#..W...................... .. >......p,o...... ... n#',#..yk6#"W5$..yyZ$..Y" Y"fi-$..WA$..WA$..WQL\ll $..WI$..WR$INWrr$..q.J$..W..&" WU&I NW±&..WK,.'WIN ............... 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