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To: Mark McIntire, NPDES Permitting Unit
From: Belinda S. Henson, Environmental Chemist, FRO Uri " i't y`�►��'
Date: February 23, 2004
Subject: Dupont's Request
NPDES Permit No. NC0003573
Bladen County
FEB 2 4 2o04
Dupont's request for rescindi g the required analyses of hexafluoroacetone
hydrate (HFA -hydrate) ' nclosed. Please review and email Paul and
myself with which ection we should follow with this. Thanks for your
assistance in th s atter.
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DL1P011t FluoroproductS
Mr. Paul Rawls
NC DENR — Division of Water Quality
225 Green Street - Suite 714
Fayetteville, NC 28301
-
DuPo tit Fit orep!educts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
February 4, 2004
SUBJECT: Request for Rescindment — 2001 NPDES Permit Addendum
NPDES Permit No. NC0003573
Dear Mr. Rawls:
In early 2001, following the discovery of an unpermitted compound,
hexafluoroacetone hydrate (HFA -hydrate), in the effluent of the DuPont - Fayetteville
Works wastewater treatment plant, the Division of Water Quality's Fayetteville Regional
Office issued an addendum to the site's NPDES permit which required this site to monitor
Outfall 001 for HFA -hydrate once each week, and report the results of that monitoring on
the monthly Discharge Monitoring Report.
Since that time, DuPont has installed and operated a new process in the Nafion®
manufacturing area that chemically destroys HFA -hydrate. The discharge from this
process is monitored internally and the area release criteria is "non-detectable" for HFA -
hydrate.
DuPont has monitored Outfall 001 weekly for HFA -hydrate for the past three years,
during which time the compound has never been detected.
The Division recently issued DuPont the renewed NPDES permit that became
effective on February 1, 2004. In this permit, monitoring for HFA -hydrate is not
specified. Therefore, the only requirement for this monitoring would be the 2001 DWQ-
FRO issued addendum.
Based on three years of submitted monitoring data in which HFA -hydrate has never
been detected, and based on the performance of the internal HFA -hydrate destruction

`Mr. Paul Rawls
Division of Water Quality
February 4, 2004
process, DuPont is requesting that DWQ-FRO rescind the 2001 NPDES permit
addendum and relieve this site from future monitoring for this compound.
Thank you for your consideration of this request. 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, FRO