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HomeMy WebLinkAboutNC0003760_Approval_20031113NPDES DOCUMENT !;CANNIN` COVER SHEET NPDES Permit: NC0003760 DuPont Kinston facility Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change /Approval _, Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: November 13, 2003 This document its printed on reuse paper - ignore any content on the rezrerse side Michael F. Easley, Governor State of North Carolina William G. Ross, Jr., Secretary Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality November 13, 2003 Mr. James R. Proctor E.I. DuPont de Nemours & Co., Inc. P.O. Box 800 Kinston, North Carolina 28502 Subject: Sludge Leachate Request Kinston Dacron® Plant NPDES Permit NC0003760 Lenoir County Dear Mr. Proctor: In your letter of July 9, you requested approval to send a new wastestream to the DuPont - Kinston Plant's industrial wastewater treatment plant (IWWTP). You wrote that DuPont is preparing to close its Ash Landfill and proposes to dewater the remaining sludge and to route the resulting leachate to its industrial wastewater treatment plant (IWWTP) for treatment and disposal. The Division has reviewed your request along with additional information you provided in your letter of September 9. Based on our review, the Division is approving the request, effective on this date and subject to the conditions described below. Your request is, in effect, a request to modify DuPont's NPDES permit application. Even though the permit has now been issued, the current application still stands as DuPont's most recent proposal to discharge from the Kinston Plant. Any change in that proposal could require a corresponding change in the permit requirements. The addition of the Ash Landfill leachate alters the list of wastestreams that the application indicates will be treated at the IWWTP. It does not appear that a permit modification is necessary in this case: you have indicated that the leachate flow will be minor (probably less than 5 gpm) compared to existing flows at the IWWTP, that previous testing detected only low levels of a few priority pollutants, and that the dewatering will probably be completed within the term of the existing NPDES permit. The Division's approval is conditioned upon DuPont taking the following steps to verify the nature and quantity of the new wastestream: Characterization. The analytical results reported for the leachate are from 1996. Once the dewatering operations are underway, DuPont must conduct new analyses to update its characterization of the leachate. Representative sample(s) should be collected during the first three months of dewatering. Analyses should include, at a minimum, BOD, COD, TSS, total nitrogen, total phosphorus, pH -I, conductivity, and a full priority pollutant scan. Leachate flow rates should be measured or estimated. Results should be reported to this office and to DWQ's Washington Regional Office within 45 days of sample collection. Duration. It is assumed that dewatering operations will be completed during the term of DuPont's current NPDES permit (expires December 31, 2007). If dewatering is still underway one year priorr to permit expiration, DuPont must repeat the sampling and analysis (as described above) in the first and second quarters of 2007 and include the results with its application for renewal. North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 (919) 733-7015 FAX (919) 733-0719 On the Internet at http://h2o.enr.state.nc.us/ Mr. James R. Proctor Sludge Leachate Request November 13, 2003 Kinston Dacron® Plant NPDES Permit NC0003760 Page 2 If any of the monitoring results or other conditions are found to be substantially different from those considered in granting this approval, the Division may revise or withdraw its approval upon written notification to the DuPont - Kinston Plant. This approval does not affect the legal requirements to obtain other permits, nor affect the conditions of those permits, that may be required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other federal or local governmental permit. If you have any questions concerning the draft permit or the other requirements for your facility, please contact me at (919) 733-5083, extension 541 or at mike.templeton@ncmail.net. CC: Sincerely, Michael E. Templeton, P.E. Washington Regional Office / Water Quality Section NPDES Files Central Files North Carolina Department of Environment and Natural Resources Division of Water Quality 512 N. Salisbury Street Raleigh, NC 27604 Attention: Mr. Michael Templeton Sept. 2, 2003 RE: REVISED REQUEST FOR ADDITION OF SLUDGE LEACHATE TO WASTEWATER TREATMENT PLANT INFLUENT KINSTON ASH LANDFILL CONSTRUCTION E.I. DUPONT KINSTON FACILITY, KINSTON, NORTH CAROLINA Dear Mr. Templeton: As discussed during our Friday, August 31, 2003 telephone conversation, the following is a revised request to add the leachate generated from the consolidation of the sludge within the Ash Landfill located within the E.I. DuPont Kinston, North Carolina facility (Site) to the site wastewater treatment plant influent diversion structure. As you may be aware, the NCDENR has mandated closure of both the C&D and Ash Landfills located within the above referenced Site. After approval of the final design by NCDENR, the C&D Landfill soil cap was constructed in January 2003. A final design for the Ash Landfill was submitted to the NCDENR in March 2003 and approved. The Ash Landfill soil cover consists of the following major stages: 1. Establishment of erosion and sedimentation (E&S) controls; 2. Clearing and grubbing; 3. Installation of a leachate collection trench at the toe of the Ash landfill; 4. Construction of a leachate conveyance system from the Ash landfill to the Site wastewater treatment plant influent structure; 5. Development of an on -site borrow area, adjacent to the Ash landfill; 6. Placement of buttress fill around the Ash landfill; 7. Installation of high strength geotextiles; 8. Placement of surcharge fill; 9. Installation of prefabricated vertical (PV) drains within the sludge pond; 10. Construction and installation of settlement platforms within the sludge pond; and 11. Placement of subsequent stages of surcharge fill and cover soils, based on settlement platform results. Construction of the soil cover over the Ash Landfill is scheduled to begin this week, and incorporates dewatering of the existing sludge pond, located within the eastern half of the landfill. Dewatering of the sludge will be accomplished through the installation of reinforcement geotextiles, prefabricated vertical (PV) geosynthetic drains, and incremental placement of a surcharge fill. Due to nature of the sludge (essentially zero c SEP — 8 2003 Michael Templeton — NCDENR -2- Sept. 2. 2003 shear strength), surcharging will be performed in stages to allow the sludge to increase its shear strength with the decrease in liquid (leachate). The existing sludge within the Ash Landfill was transported from the trade waste aeration basin in October 1985. It is estimated that 1.2 million gallons of wet sludge were placed at that time. Analytical results on both sludge and ash samples, obtained in 1996, show negligible concentrations of a few organic compounds and metals. All of these constituents are present in concentrations below Federal Maximum Contaminant Limits (MCLs). The Ash Landfill leachate will be transported by gravity to the existing wastewater treatment plant influent diversion structure on Site through an underground leachate conveyance system. Due to the nature of the sludge, the leachate quantity or flow rate cannot be accurately estimated, but is believed to be less than 5 gallons per minute (gpm). The duration of this flow is unknown at this time, but, as discussed, will be temporary, as the sludge will only consolidate as a function of the intensity of the surcharge load. It is understood that the NCDENR may request the Kinston facility to sample the transported leachate for characterization purposes. This program will be addressed in separate correspondence. We hope this information is sufficient for your needs. If you have any questions, please contact me at 252-522-6443. Sincerely, E.I. DUPONT KINSTON PLANT James R. Proctor Environmental Specialist cc: James E. Whitty — URS Diamond, Wilmington Andrew Alcazar — DuPont CRG, Charlotte Mac Bonner — URS Diamond, Wilmington Tyson Campbell - URS Diamond, Wilmington C:IDOCUME--11PROCTOJR\LOCALS-11Temp\ncdenr templeton It 9-2-03.doc North Carolina Department of Environment and Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Attention: Mr. Michael Templeton July 9, 2003 RE: REQUEST FOR ADDITION OF SLUDGE LEACHATE TO WASTEWATER 7, TREATMENT PLANT ^-4,`\.`� KINSTON ASH LANDFILL CONSTRUCTION DTI KINSTON FACILITY, KINSTON, NORTH CAROLINA re're" Dear Mr. Templeton: As discussed with Mr. James Proctor of DTI Kinston, the following is a formal request to add the leachate generated from the sludge within the Ash Landfill located within the DTI Kinston, North Carolina facility (Site) to the site wastewater treatment plant. As you may be aware, NCDENR has mandated closure of both the C&D and Ash Landfills located from the above referenced Site. After approval of the final design by NCDENR, the C&D Landfill soil cap was constructed early in 2003. A final design for the Ash Landfill has been submitted to the NCDENR and approved. Construction of the soil cover over the Ash Landfill is scheduled to begin shortly, and incorporates dewatering of the existing sludge pond, located within the eastern half of the landfill. Dewatering of the sludge will be accomplished through the installation of a reinforcement geotextile, prefabricated vertical (PV) geosynthetic drains, and placement of a surcharge load. Due to nature of the sludge (essentially zero shear strength), surcharging will be performed in stages to allow the sludge to increase its shear strength with the decrease in liquid (leachate). The existing sludge within the Ash Landfill was transported from the trade waste aeration basin in October 1985. It is estimated that 1.2 million gallons of wet sludge were placed at that time. Analytical results on both sludge and ash samples, obtained in 1996, are presented in Attachment 1. These results show negligible concentrations of a few organic compounds and metals. All of these constituents are present in levels below Federal Maximum Contaminant Limits (MCLs).. The Ash Landfill leachate will be transported by gravity to the existing wastewater treatment plant influent diversion structure on Site through an underground leachate conveyance system. Due to the nature of the sludge, the leachate quantity or flow rate cannot be accurately estimated, but is believed to be less than 5 gallons per minute (gpm). Eaaz z inr Michael Templeton — NCDENR -2- July 9, 2003 We hope this information is sufficient for your needs. If you have any questions, please contact me at 302-992-6846. fQ/5k S1� Sincerely, URS Diamond James E. Whitty, P.E. Principal Engineer Attachment cc: James Proctor — DTI, Kinston Andrew Alcazar — CRG, Charlotte Mac Bonner — URS Diamond C:IDOCUMFr11PROCTOJRILOCALS-11TemplTempleton Letter.doc Attachment 1 - Summary of Ash and Sludge Analytical Results DTI Kinston Facility Sample ID BIO-SLUDGE F/B-ASH Date 4/22/1996 4/22/1996 Top (ft) Total (T)/ Bottom (ft) Analyte units Diss. (D) Duplicate # 1 1 1,1,1,2-TETRACHLOROETHANE ugA T ND (1.) ND (1.) 1,1,1-TRICHLOROETHANE ugA T ND (1.) ND (1.) 1,1,2,2-TETRACHLOROETHANE ug/l T ND (2.) ND (2.) 1,1,2-TRICHLOROETHANE ug/1 T ND (2.) ND (2.) 1,1-DICHLOROETHANE ugA T ND (2.) ND (2.) 1,1-DICHLOROETHENE ugA T ND (1.) ND (1.) 1,2,3-TRICHLOROPROPANE ugA T ND (1.) ND (1.) 1,2-DIBROMO-3-CHLOROPROPANE ugA T ND (3.) ND (3.) 1,2-DIBROMOETHANE ugA T ND (1.) ND (1.) 1,2-DICHLOROETHANE ugA T ND (2.) ND (2.) 1,2-DICHLOROPROPANE ugA T ND (1.) ND (1.) 1,4-DIOXANE ugA T ND (70.) ND (70.) 2-HEXANONE ugA T ND (7.) ND (7.) ACETONE ugA T ND (6.) ND (6.) ACETONITRILE ugA T ND (25.) ND (25.) ACROLEIN ugA T ND (40.) ND (40.) ACRYLONITRILE ugA T ND (10.) ND (10.) ALLYL CHLORIDE ugA T ND (1.) ND (1.) BENZENE ugA T ND (1.) ND (1.) BROMODICHLOROMETHANE ugA T ND (1.) ND (1.) BROMOFORM ugA T ND (1.) ND (1.) CARBON DISULFIDE ugA T ND (3.) ND (3.) CARBON TETRACHLORIDE ug/1 T ND (1.) ND (1.) CHLOROBENZENE ug/1 T ND (1.) ND (1.) CHLOROETHANE ug/1 T ND (3.) ND (3.) CHLOROFORM ugA T ND (1.) ND (1.) CHLOROPRENE ugA T ND (2.) ND (2.) CIS-1,2-DICHLOROETHENE ugA T ND (2.) ND (2.) CIS-1,3-DICHLOROPROPENE ugA T ND (1.) ND (1.) DIBROMOCHLOROMETHANE ugA T ND (2.) ND (2.) DIBROMOMETHANE ugA T ND (1.) ND (1.) DICHLORODIFLUOROMETHANE ugA T ND (2.) ND (2.) ETHYL METHACRYLATE ugA T ND (1.) ND (1.) ETHYLBENZENE ugA T ND (2.) ND (2.) - IODOMETHANE ugA T ND (1.) ND (1.) ISOBUTYL ALCOHOL ugA T ND (100.) ND (100.) METHACRYLONITRILE ugA T ND (10.) ND (10.) METHYL BROMIDE ugA T ND (3.) ND (3.) METHYL CHLORIDE ugA T ND (3.) ND (3.) METHYL ETHYL KETONE ugA T ND (3.) ND (3.) =METHYL METHACRYLATE ugA T ND (1.) ND (1.) METHYL -ISO -BUTYL KETONE ugA T ND (5.) ND (5.) METHYLENE CHLORIDE ugA T ND (2.) ND (2.) PENTACHLOROETHANE ug/1 T ND (1.) ND (1.) G STYRENE ug/1 T ND (1.) ND (1.) - TETRACHLOROETHENE ugA T ND (1.) ND (1.) TOLUENE ugA T ND (2.) ND (2.) - TRANS-1,2-DICHLOROETHENE ugA T ND (2.) ND (2.) TRANS-1,3-DICHLOROPROPENE ugA T ND (1.) ND (1.) TRANS-1,4-DICHLORO-2-BUTENE ugA T ND (15.) ND (15.) TRICHLOROETHENE ugA T ND (1.) ND (1.) TRICHLOROFLUOROMETHANE ugA T ND (2.) ND (2.) VINYL ACETATE ugA T ND (2.) ND (2.) VINYL CHLORIDE ugA T ND (2.) ND (2.) XYLENES (TOTAL) ugA T ND (1.) ND (1.) 1,2,4,5-TETRACHLOROBENZENE ugA T ND (1.) ND (1.) 1,2,4-TRICHLOROBENZENE ugA T ND (1.) ND (1.) 1,2-DICHLOROBENZENE ugA T ND (1.) ND (1.) 1,3,5-TRINITROBENZENE ugA T ND (5.) ND (5.) 1,3-DICHLOROBENZENE ugA T ND (1.) ND (1.) 1,4-DICHLOROBENZENE ugA T ND (1.) ND (1.) 1,4-NAPHTHOQUINONE ugA T ND (1.) ND (1.) < and ND = Non detect at stated reporting limit Page 1 of 4 Kinston Ash Landfill Historical Data:Sheetl 7/23/2003 9:46 AM Attachment 1 - Summary of Ash and Sludge Analytical Results DTI Kinston Facility Sample ID BIO-SLUDGE FIB -ASH Date 4/22/1996 4/22/1996 Top (ft) Total (T)I Bottom (ft) Analyte units Diss. (D) Duplicate # 1 1 1-NAPHTHYLAMINE ugA T ND (2.) ND (2.) 2,3,4,6-TETRACHLOROPHENOL ugA T ND (2.) ND (2.) 2,4,5-TRICHLOROPHENOL ug/I T ND (1.) ND (1.) 2,4,6-TRICHLOROPHENOL ugA T ND (1.) ND (1.) 2,4-DICHLOROPHENOL ug/1 T ND (2.) ND (2.) 2,4-DIMETHYLPHENOL ugA T ND (1.) ND (1.) 2,4-DINITROPHENOL ugA T ND (5.) ND (5.) 2,4DINITROTOLUENE ug/I T ND (2.) ND (2.) 2,6-DICHLOROPHENOL ugA T ND (1.) ND (1.) 2,6-DINITROTOLUENE ugA T ND (1.) ND (1.) 2-ACETYLAMINOFLUORENE ugA T ND (2.) ND (2.) 2-CHLORONAPHTHALENE ugA T ND (1.) ND (1.) 2-CHLOROPHENOL ugA T ND (1.) ND (1.) 2-METHYLNAPHTHALENE ugA T ND (1.) ND (1.) 2-NAPHTHYLAMINE ugA T ND (2.) ND (2.) 2-NITROPHENOL ugA T ND (2.) ND (2.) 2-PICOLINE ug/I T ND (1.) ND (1.) 2-SEC-BUTYL-4,6-DINITROPHENOL ugA T ND (.07) ND (.07) 3 OR 4-METHYLPHENOL ugA T ND (2.) ND (2.) 3,3'-DICHLOROBENZIDINE ugA T ND (2.) ND (2.) 3,3'-DIMETHYLBENZIDINE ugA T ND (2.) ND (2.) 3-METHYLCHOLANTHRENE ugA T ND (2.) ND (2.) 4,6-DINITRO-2-METHYLPHENOL ugA T ND (5.) ND (5.) 4-AMINOBIPHENYL ug/1 T ND (1.) ND (1.) 4-BROMOPHENYL PHENYL ETHER ugA T ND (2.) ND (2.) 4CHLOR0-3-METHYLPHENOL ugA T ND (2.) ND (2.) 4-CHLOROANILINE ug/I T ND (2.) ND (2.) 4-CHLOROPHENYL PHENYL ETHER ugA T ND (2.) ND (2.) 4-NITROPHENOL ugA T ND (5.) ND (5.) 4-NITROQUINOLINE-N-OXIDE ugA T ND (10.) ND (10.) 5-NITRO-O-TOLUIDINE ugA T ND (2.) ND (2.) 7,12-DIMETHYLBENZO(A)ANTHRACENE ugA T ND (2.) ND (2.) A-A-DIMETHYLPHENETHYLAMINE ugA T NO (1.) ND (1.) ACENAPHTHENE ugA T ND (1.) ND (1.) ACENAPHTHYLENE ug/1 T ND (1.) ND (1.) ACETOPHENONE ugA T ND (2.) ND (2.) ANILINE ugA T ND (2.) ND (2.) ANTHRACENE ug/I T ND (1.) ND (1.) BENZO(A)ANTHRACENE ugA T ND (1.) ND (1.) BENZO(A)PYRENE ugA T ND (2.) ND (2.) BENZO(B)FLUORANTHENE ugA T ND (2.) ND (2.) BENZO(G,H,I)PERYLENE ugA T ND (2.) ND (2.) BENZO(K)FLUORANTHENE ugA T ND (2.) ND (2.) 3. J ND (1.) BENZYL ALCOHOL ugA T 3. J BIS(2-CHLOROETHOXY)METHANE ugA T ND (1.) BIS(2-CHLOROETHYL) ETHER ugA T ND (1.) ND (1.) BIS(2-CHLOROISOPROPYL)ETHER ugA T ND (2.) ND (2.) BIS(2-ETHYLHEXYL)PHTHALATE ugA T ND (2.) ND (2.) BUTYL BENZYL PHTHALATE ugA T ND (2.) ND (2.) CHLORDANE ugA T ND (.1) ND (.07) CHLOROBENZILATE ugA T ND (4.) ND (4.) CHRYSENE ugA T ND (1.) ND (1.) DI-N-BUTYL PHTHALATE ugA T 92 ND (1.) DI-N-OCTYL PHTHALATE ug/I T ND (2.) ND (2.) DIALLATE ugA T ND (2.) ND (2.) DIBENZO(A,H)ANTHRACENE ug/1 T ND (2.) ND (2.) DIBENZOFURAN ugA T ND (1.) ND (1.) DIETHYL PHTHALATE ugA T ND (2.) ND (2.) DIMETHOATE ugA T ND (2.) ND (2.) DIMETHYL PHTHALATE ugA T ND (3.) ND (3.) ETHYL METHANESULFONATE ugA T ND (1.) ND (1.) FLUORANTHENE ugA T ND (1.) ND (1.) < and ND = Non detect at stated reporting limit Page 2 of 4 Kinston Ash Landfill Historical Data:Sheetl 7/23/2003 9:46 AM Attachment 1 - Summary of Ash and Sludge Analytical Results DTI Kinston Facility Sample ID BIO-SLUDGE F/B-ASH Date 4/22/1996 4/22/1996 Top (ft) Total (T)/ Bottom (ft) Analyte units Diss. (D) Duplicate # 1 1 FLUORENE ugA T ND (1.) ND (1.) HEXACHLOROBENZENE ugA T ND (1.) ND (1.) HEXACHLOROBUTADIENE ugA T ND (1.) ND (1.) HEXACHLOROCYCLOPENTADIENE ug/1 T ND (3.) ND (3.) HEXACHLOROETHANE ug/ T ND (2.) ND (2.) HEXACHLOROPROPENE ug/I T ND (2.) ND (2.) INDENO(1,2,3-CD)PYRENE ug/I T ND (2.) ND (2.) ISODRIN ug/1 T ND (1.) ND (1.) ISOPHORONE ug/1 T ND (1.) ND (1.) ISOSAFROLE ug/ T ND (1.) ND (1.) M-DINITROBENZENE ug/I T ND (2.) ND (2.) M-NITROANILINE ug/1 T ND (1.) ND (1.) METHAPYRILENE ug/1 T ND (1.) ND (1.) METHYL METHANESULFONATE ugA T ND (1.) ND (1.) N-NITROSO-DI-N-BUTYLAMINE ug/ T ND (2.) ND (2.) N-NITROSODI-N-PROPYLAMINE ug/I T ND (2.) ND (2.) N-NITROSODIETHYLAMINE ug/l T ND (2.) ND (2.) N-NITROSODIMETHYLAMINE ugl T ND (2.) ND (2.) N-NITROSODIPHENYLAMINE ug/l T ND (2.) ND (2.) N-NITROSOMETHYLETHYLAMINE ug/1 T ND (2.) ND (2.) N-NITROSOMORPHOLINE ug/I T ND (1.) ND (1.) N-NITROSOPIPERIDINE ug/1 T ND (2.) ND (2.) N-NITROSOPYRROLIDINE ugA T ND (2.) ND (2.) NAPHTHALENE ug/ T ND (1.) ND (1.) NITROBENZENE ug/I T ND (1.) ND (1.) O,O,O-TRIETHYL PHOSPHOROTHIOAT ug/1 T ND (2.) ND (2.) O-CRESOL ug/1 T ND (2.) ND (2.) O-NITROANILINE ug/I T ND (1.) ND (1.) O-TOLUIDINE ugA T ND (2.) ND (2.) P-DIMETHYLAMINOAZOBENZENE ug/I T ND (1.) ND (1.) P-NITROANILINE ug/I T ND (2.) ND (2.) P-PHENYLENEDIAMINE ug/1 T ND (20.) ND (20.) PENTACHLOROBENZENE ug/1 T ND (1.) ND (1.) PENTACHLORONITROBENZENE ug/l T ND (2.) ND (2.) PENTACHLOROPHENOL ug/I T ND (1.) ND (1.) PHENACETIN ug/1 T ND (2.) ND (2.) PHENANTHRENE ugl T ND (1.) ND (1.) PHENOL ug/I T ND (1.) ND (1.) PRONAMIDE ug/1 T ND (1.) ND (1.) PROPIONITRILE ug/I T ND (30.) ND (30.) PYRENE ug/I T ND (1.) ND (1.) PYRIDINE ug/I T ND (2.) ND (2.) SAFROLE ug/1 T ND (2.) ND (2.) TETRAETHYLDITHIOPYROPHOSPHATE ugl T ND (2.) ND (2.) 2,4,5-T ug/ T ND (.05) ND (.05) 2,4,5-TP (SILVEX) ug/l T ND (.04) ND (.04) 2,4-D ug/1 T ND (.1) ND (.1) AROCLOR 1016 ug/ T ND (.07) ND (.07) AROCLOR 1221 ug/I T ND (.1) ND (.1) AROCLOR 1232 ugA T ND (.08) ND (.08) AROCLOR 1242 ug/I T ND (.04) ND (.04) AROCLOR 1248 ug/ T ND (.06) ND (.06) AROCLOR 1254 ug/1 T ND (.05) ND (.05) AROCLOR 1260 ug/ T ND (.06) ND (.06) 4,4'-DDD ugl T ND (.006) ND (.006) 4,4-DDE ug/1 T ND (.005) ND (.005) 4,4'-DDT ug/I T 0.01 ND (.007) ALDRIN ug/I T ND (.04) ND (.004) ALPHA-BHC ug/I T ND (.002) ND (.002) BETA-BHC ug/I T ND (.07) ND (.007) DELTA-BHC ug/1 T ND (.004) ND (.004) DIELDRIN ug/1 T ND (.005) ND (.005) < and ND = Non detect at stated reporting limit Page 3 of 4 IGnston Ash Landfill Historical Data:Sheetl 7/23/2003 9:46 AM Attachment 1 - Summary of Ash and Sludge Analytical Results DTI Kinston Facility Sample ID BIO-SLUDGE FIB -ASH Date 4/22/1996 4/22/1996 Top (ft) Total (T)1 Bottom (ft) Analyte units Diss. (D) Duplicate # 1 1 ENDOSULFAN I ugA T ND (.03) ND (.003) ENDOSULFAN II ug/I T ND (.009) ND (.009) ENDOSULFAN SULFATE ugA T ND (.006) ND (.006) ENDRIN ugA T ND (.005) ND (.005) ENDRIN ALDEHYDE ug/I T ND (.008) ND (.008) GAMMA-BHC ugA T ND (.02) ND (.002) HEPTACHLOR ugA T ND (.004) ND (.004) HEPTACHLOR EPDXIDE ugA T ND (.003) ND (.003) KEPONE ugA T ND (.3) ND (.3) METHOXYCHLOR ugA T ND (.03) ND (.03) THIONAZIN ugA T ND (2.) ND (2.) TOXAPHENE ugA T ND (.9) 5.2 J ND (2.7) 580 ND (1.3) ND (.9) ANTIMONY ugA T ND (3.1) ARSENIC ugA T ND (2.7) 310 ND (1.3) BARIUM ug/I T BERYLLIUM ugA T CADMIUM ugA T ND (2.7) ND (2.7) CHROMIUM ugA T ND (4.3) ND (4.3) 33.0 J ND (3.8) COBALT ugA T ND (5.5) COPPER ugA T ND (3.8) LEAD ugA T ND (2.0) ND (2.0) MERCURY ugA T ND (.043) ND (.040) 50 ND (2.7) NICKEL ugA T ND (5.4) SELENIUM ugA T ND (2.7) SILVER ug/I T ND (3.6) ND (3.6) 4.7 J ND (25) THALLIUM ugA T ND (4.5) TIN ugA T ND (25) VANADIUM ugA T ND (7.0) 206 35 ND (500) ND (7.0) 252 ND (4) ZINC ugA T CYANIDE, TOTAL ugA T -SULFIDE AS S ugA T I ND (500) < and ND = Non detect at stated reporting limit Kinston Ash Landfill Historical Data:Sheetl Page 4 of 4 7/23/2003 9:46 AM mailbox:///Cl/Documents%20and%20Settings/shannon_thornburg/App... Subject: Re: dupont (a.k.a. dti) leachate letter From: Shannon Thornburg <shannon.thornburg@ncmail.net> Date: Wed, 03 Sep 2003 11:44:20 -0400 To: Mike Templeton <mike.templeton @ncmail.net> CC: Al Hodge <Al.Hodge@ncmail.net>, Christie Jackson <Christie.Jackson@ncmail.net>, Charles Weaver <Charles.Weaver@ncmail.net> Thanks for the clarification, Mike! I will assume that further involvement from NDPU is not needed. I will send you the information that I have collected on this issue this afternoon. Shannon Mike Templeton wrote: Shannon & Al - I spoke with Jim Twitty of URS and James Proctor of DuPont - Kinston this afternoon about the mystery letter of July 9. Here's what I got out of it. First, DTI (DuPont Textile Interiors) is an internal working name for a group of plants that DuPont is selling to Koch. It sounds like they have made the deal and are going through the paperwork. Once the change is made, they will apply for ownership changes for their permits. The Kinston plant has closed one landfill (the C&D Landfill) and is in the process of closing another (the Ash Landfill). The Ash Landfill has coal ash and wet sludge and has to be dewatered before they can cap it. They propose to install a filtered drainage system in the sludge, cover it with a layer of geotextile, and gradually add clean soil cover to squeeze the water out, similar to a large-scale belt press. They then propose to drain the "filtrate" by gravity to DuPont's existing WWTP for treatment and discharge. Flow would be up to 5 gpm and would continue for several months to several years, depending on how readily the dewatering proceeds. No sludge or water will leave the landfill except what drains from the landfill to the WWTP. Certainly none will go to the City of Kinston's facilities. James P will give the City a courtesy call to clarify this and put the City at ease. Shannon, there don't appear to be any sludge issues that affect you directly. DuPont has worked with Jim Barber (Raleigh) and John Crowder (WaRO) of Solid or Haz Waste on the closure, and they may know more about it. Would you be interested in calling them to see what light they can shed on this? Al, I think the rest of this is for you. DuPont needs to submit a more thorough description of their proposal, as an amendment to the most recent application in the files. James P indicated they will get that to Raleigh next week; I'll forward a copy to you. We can decide whether it needs a permit mod and respond accordingly. Based on what I know from this phone call and their letter, I'm fairly comfortable approving it without changing their permit. The flow is insignificant compared to their existing flows, and the one scan yielded very few hits on priority pollutants. It shouldn't present a problem at the WWTP, and it's their responsibility if it does. On the other hand, they only collected one sample from the whole landfill and that dates 1 of 2 9/3/2003 11:44 AM mailbox:///Cl/Documents%20and%20Settings/shannon_thornburg/App... from 1996. On -going monitoring of some sort may be called for, through the permit or by letter. I'd like to hear your thoughts on all of this, either now or after you've looked at the next submittal - or both. That's it for today. I'll talk to you guys next week. - Mike T Michael E. Templeton, P.E. North Carolina Division of Water Quality NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 919-733-5083 x541 FAX: 919-733-0719 mailto:mike.templeton@ncmail.net 2of2 9/3/2003 11:44 AM Re: dupcitnt (a.k.a. clti) leachate letter z Subject: Date: From: Organization: To: CC: Re: dupont (a.k.a. dti) leachate letter Wed, 03 Sep 2003 11:44:20 -0400 Shannon Thornburg <shannon.thornburg@ncmail.net> NC DENR DWQ Mike Templeton <mike.templeton@ncmail.net> Al Hodge <Al.Hodge@ncmail.net>, Christie Jackson <Christie.Jackson@ncmail.net>, Charles Weaver <Charles.Weaver@ncmail.net> Thanks for the clarification, Mike! I will assume that further involvement from NDPU is not needed. I will send you the information that I have collected on this issue this afternoon. Shannon Mike Templeton wrote: >Shannon & Al - >1 spoke with Jim Twitty of URS and James Proctor of DuPont - Kinston >this afternoon about the mystery letter of July 9. Here's what 1 got out >of it. >First, DTI (DuPont Textile Interiors) is an internal working name for a >group of plants that DuPont is selling to Koch. It sounds like they have >made the deal and are going through the paperwork. Once the change is >made, they will apply for ownership changes for their permits. >The Kinston plant has closed one landfill (the C&D Landfill) and is in >the process of closing another (the Ash Landfill). The Ash Landfill has >coal ash and wet sludge and has to be dewatered before they can cap it. >They propose to install a filtered drainage system in the sludge, cover >it with a layer of geotextile, and gradually add clean soil cover to >squeeze the water out, similar to a large-scale belt press. They then >propose to drain the 'filtrate" by gravity to DuPont's existing WWTPfor >treatment and discharge. Flow would be up to 5 gpm and would continue >for several months to several years, depending on how readily the >detvatering proceeds. >No sludge or water will leave the landfill except what drains from the >landfill to the WWTP. Certainly none will go to the City of Kinston's >facilities. James P will give the City a courtesy call to clarify this >and put the City at ease. >Shannon, there don't appear to be any sludge issues that affect you >directly. DuPont has worked with Jim Barber (Raleigh) and John Crowder >(WaRO) of Solid or Haz Waste on the closure, and they may know more >about it. Would you be interested in calling them to see what light they 1 of 2 9/5/038:57A1V Re: clupant (a.k.a. dti) leachate letter >can shed on this? >AI, I think the rest of this is for you. >DuPont needs to submit a more thorough description of their proposal, as >an amendment to the most recent application in the files. James P >indicated they will get that to Raleigh next week; I'll forward a copy >to you. We can decide whether it needs a permit mod and respond >accordingly. >Based on what I know from this phone call and their letter, I'm fairly >comfortable approving it without changing their permit. The flow is >insignificant compared to their existing flows, and the one scan yielded >very few hits on priority pollutants. It shouldn't present a problem at >the WWTP, and it's their responsibility fit does. On the other hand, >they only collected one sample from the whole landfill and that dates >from 1996. On -going monitoring of some sort may be called for, through >the permit or by letter. I'd like to hear your thoughts on all of this. >either now or after you've looked at the next submittal - or both. >That's it for today. I'll talk to you guys next week. >- Mike T >- >Michael E. Templeton, P.E. >North Carolina Division of Water Quality >NPDES Unit >1617 Mail Service Center, Raleigh, NC 27699-1617 >9I9-733-5083 x541 FAX: 919-733-0719 >mailto:mike.templeton@ncmail.net 2of2 9/5/038:57AN.