DEQp00021981

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Ms. Teresa Rodriguez
NCDENR Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699 - 1617
SUBJECT: NPDES Permit Renewal Application Addendum
Revised Form 2C and Supplemental Information
NPDES Permit No. NC0003573
Dear Ms. Rodriguez:
DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
August 2, 2006
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AUG 4 2006
DENR - WATER QUALM
POINT SOURCE BE
Enclosed are the revised Form 2C submittals for the subject renewal application. These
forms include the omitted analytical data. Outfall 002 sampling showed unexpected positive
results for cyanide, chloroform, dichlorobromomethane, and bis(2-ethylhexyl)phthalate; none of
which are used or produced at this site.
Also, you will find a revised Supplemental Information document that describes the
proposed changes with the construction of a new manufacturing unit that will produce Polyvinyl
Fluoride (PVF) polymer resins. It has been determined that the preferred means of controling
solids from the PVF unit is a new clarifier which will be dedicated to the PVF wastewater. The
discharge from this clarifier will be to the existing Outfall 001. Therefore, please ignore the
original submittal's description of the PVF treated wastewater being discharged through and
monitored at Outfall 006.
A revised water balance sheet is enclosed which reflects the above treatment change.
Should you have any questions, please feel free to call me at [phone].
Michael E. Johnson
Environmental Manager
Enclosures
E.I. du Pont de Nemours and Company

DuPont Company – Fayetteville Works NPDES Permit No. NC0003573
Supplemental Information (Revised)
Revised Supplemental Information – Permit Renewal Application – August 1, 2006
Proposed Chances in Operations
PVF Manufacturine Facility: The DuPont Company – Fayetteville Works has been selected as
the location for the DuPontTM Polyvinyl Fluoride (PVF) manufacturing process. The
manufacturing facility is in the process of being designed, and will produce PVF polymer resins.
PVF resin to be manufactured at the Fayetteville plant is used in DuPontTM Tedlar®
fluoropolymer film business. Tedlar® film is manufactured at other DuPont site location (not
the Fayetteville plant). Tedlar® is used in the photovoltaic industry in photovoltaic cells and the
aircraft industry for interior cabin surfaces, as well as many other uses. This new facility
construction will be completed in August 2007 and begin start up in October 2007.
The manufacturing facility will be located near the existing Teflon® FEP resin manufacturing
area. This process will produce polyvinyl fluoride (PVF) resin (CAS No. 24981-14-4).
As with most fluorochemical processes, the wastewater from the PVF manufacturing process is
expected to have very little or no biological oxygen demand (BODS) value. Treatability tests
have been performed on samples from another DuPont site which currently manufactures PVF.
These studies have indicated use of non -biological treatment will meet effluent limitation of
OCPSF NSPS guidelines of Subpart D—Thermoplastic Resins (40 CFR 414.40). DuPont will
control solids in the wastewater from this new facility via a new dedicated clarifier whose
discharge will go directly to Outfall 001.
A suggested change to the language of the current permit's narrative in the "Supplement To
Permit Cover Sheet" that would accommodate the new PVF Manufacturing Facility follows:
Continue to operate existing wastewater treatment facilities consisting of-
equalization;
fequalization; (etc)
2. To operate new wastewater treatment facilities consisting of
• clarifier for PVF process wastewater;
3. Discharge treated process wastewater from Butacite, Nafion, PVF, and Teflon® PMDF,
process stormwater, sanitary wastewater, and co -neutralized regenerate form said treated
facilities through internal outfall 001;
The process wastewater is expected to contain unreacted vinyl fluoride (CAS No. 00075-02-5).
The anticipated quantity of vinyl fluoride from the PVF Manufacturing Facility is 0.312 pounds
per day. This quantity would equate to approximately 0.04 mg/L vinyl fluoride at Outfall 001
and 0.0035 mg/L vinyl fluoride at Outfall 002.
Finally, non -contact cooling, condensate, and stormwater from the PVF Manufacturing Facility
will be discharged directly to Outfall 002 via the site's Woodlined Ditch.
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DuPont Company – Fayetteville Works NPDES Permit No. NC0003573
Supplemental Information (Revised)
Revised Supplemental Information – Permit Renewal Application – August 1, 2006
Proposed Changes in Operations
PVF Manufacturina Facility: The DuPont Company – Fayetteville Works has been selected as
the location for the DuPontTM Polyvinyl Fluoride (PVF) manufacturing process. The
manufacturing facility is in the process of being designed, and will produce PVF polymer resins.
PVF resin to be manufactured at the Fayetteville plant is used in DuPontTM Tedlar®
fluoropolymer film business. TedlarO film is manufactured at other DuPont site location (not
the Fayetteville plant). Tedlar® is used in the photovoltaic industry in photovoltaic cells and the
aircraft industry for interior cabin surfaces, as well as many other uses. This new facility
construction will be completed in August 2007 and begin start up in October 2007.
The manufacturing facility will be located near the existing Teflon® FEP resin manufacturing
area. This process will produce polyvinyl fluoride (PVF) resin (CAS No. 24981-14-4).
As with most fluorochemical processes, the wastewater from the PVF manufacturing process is
expected to have very little or no biological oxygen demand (BODS) value. Treatability tests
have been performed on samples from another DuPont site which currently manufactures PVF.
These studies have indicated use of non -biological treatment will meet effluent limitation of
OCPSF NSPS guidelines of Subpart D—Thermoplastic Resins (40 CFR 414.40). DuPont will
control solids in the wastewater from this new facility via a new dedicated clarifier whose
discharge will go directly to Outfall 001.
A suggested change to the language of the current permit's narrative in the "Supplement To
Permit Cover Sheet" that would accommodate the new PVF Manufacturing Facility follows:
Continue to operate existing wastewater treatment facilities consisting of:
• equalization; (etc)
2. To operate new wastewater treatment facilities consisting of:
• clarifier for PVF process wastewater;
3. Discharge treated process wastewater from Butacite, Nafion, PVF, and Teflon® PMDF,
process stormwater, sanitary wastewater, and co -neutralized regenerate form said treated
facilities through internal outfall 001;
The process wastewater is expected to contain unreacted vinyl fluoride (CAS No. 00075-02-5).
The anticipated quantity of vinyl fluoride from the PVF Manufacturing Facility is 0.312 pounds
per day. This quantity would equate to approximately 0.04 mg/L vinyl fluoride at Outfall 001
and 0.0035 mg/L vinyl fluoride at Outfall 002.
Finally, non -contact cooling, condensate, and stormwater from the PVF Manufacturing Facility
will be discharged directly to Outfall 002 via the site's Woodlined Ditch.

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