NC0003760_Permit (Modification)_20111031

NPDES DOCUMENT SCANNING COVER SHEET
NPDES Permit:
NC0003760
DuPont Kinston facility
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
:'"r
Permit Modificatio >
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Technical Correction
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
October 31, 2011
This document is printed on reuse paper - igriore any
content on the reYerse side

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
October 31, 2011
Alex Torres
Environmental and Safety Manager
E. I. DuPont Kinston Plant
P. O. Box 800
Kinston, NC 28502-0800
Subject: Issuance of Minor Permit Modification--_-
NPDES Permit NC0003760
E. I. DuPont Kinston Plant
Lenoir County
Dear Mr. Torres:
•
Division personnel have reviewed and approved your request to extend the Acrolein compliance date
and two milestone dates in your NPDES permit by four months. As a minor modification with justification, the
statutes allow a one time maximum four month extension. Accordingly, we are forwarding the attached
modified NPDES permit pages. These modified pages should be inserted into your permit and =the.. old ones
discarded. This modified permit is issued pursuant to the requirements of North Carolina GeneralrStatute 143-
215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection
Agency dated October 15, 2007 (or as subsequently amended).
If you have any questions concerning this permit, please contact Ron Berry at telephone number (919)
807-6396 or at email [e-mail].
oleen H. Sullins
Attachments
Cc: Washington Regional Office/Surface Water Protection Section
EPA Region IV/Pam Myers (email)
NPDES File
Central File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: httpl! h2o.state.nc.us /
An Equal Opportunity\Affirmative Action Employer
No7rthCarolina
Naturally

A.(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — OUTFALL 001 (Continued)
Footnotes:
1) Sample locations: I - Influent, E — Effluent, S1 - Chlorine contact chamber or other approved location, U — Upstream,
100 yard above outfall, D — Downstream, 1 mile below outfall.
2) For a given wastewater sample, TN = TKN + (NO3-N + NO2-N), where TN is Total Nitrogen, TKN is Total Kjeldahl
Nitrogen, and (NO3-N + NO2-N) are Nitrate and Nitrite Nitrogen, respectively.
3) TN Load is the mass quantity of TN discharged in a given period of time. See Special Condition A.(5.), Calculation of
Total Nitrogen Loads.
4) Compliance with this limit shall be determined in accordance with Special Condition A.(6.) of this permit, Annual
Limits for Total Nitrogen.
5) The quarterly average for total phosphorus shall be the average of composite samples collected weekly during the
calendar quarter (January -March, April -June, July -September, October -December).
6) Monthly monitoring/reporting shall continue with limits taking effect January 1, 2014; see Condition A.(21.).
7) Chronic Toxicity (Ceriodaphnia) P/F at 1.9%; January, April, July, and October; see Condition A.(8.), Chronic Toxicity
Permit Limit.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no addition of chromium, zinc, or copper to the cooling water systems except as components of
pre -approved biocidal compounds. See Condition A.(9.).
Part I, Page 2 of 19

Permit NC0003760
A.(20.) MONITORING REQUIREMENTS FOR ON -SITE VEHICLE MAINTENANCE
Facilities which have any vehicle maintenance activity occurring on -site which uses more than 55 gallons of new
motor oil per month, averaged over the calendar year, shall monitoring as specified additional discharge
characteristics in any stormwater outfall that contains a vehicle maintenance area stormwater runoff. All
monitoring shall be performed during a representative storm event' at storm water outfall (SDO) and shall meet
requirements in Special Condition A.(19.) Benchmark Compliance and Tiers,
Discharge Characteristics'-
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Sample`
,Location 4a•
.. Y ..
Total Petroleum Hydrocarbons
(TPH)
semi-annual
Grab
15 mg/L
SDO
New Motor Oil Usage,
gallons /month
semi-annual
Estimate
Footnotes:
1. A representative stormwater event is a storm event that measures greater than 0.1 inches of
rainfall. The time between this storm event and the previous storm event measuring greater than
0.1 inches must be at least 72 hours. A single storm event may have a period of no precipitation
of up to 10 hours. For example, if it rains but stops before producing any collectable discharge, a
sample may be collected if the next rain producing a•discharge begins within 10 hours.
2. Semi-annual means two times a year. See Special Condition A.(16.) Monitoring Schedule.
3. Grab samples shall be collected within the first 30 minutes of flow at the SDO. If the stormwater
runoff is controlled by a stormwater detention pond a grab sample of the discharge from the pond
shall be collected within the first 30 minutes of discharge from the pond.
4. Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that
discharges stormwater runoff from area(s) where vehicle maintenance activities occur.
A.(21.) ACROLEIN COMPLIANCE SCHEDULE
To allow the Permittee to isolate the source, evaluate the best process change or treatment method, and then
implement the necessary action, acrolein limits will take effect January 1, 2014. The Permittee must complete
each milestone and submit a written status report on the milestone date. Non -submittal by the milestone date will
be considered out of compliance and subject to enforcement action.'
1) MILESTONE 1 - COMPLETION OF THE EVALUATION PROCESS — April 1, 2012
Permittee completed generation of process wastewater data for acrolein for all Process and Waste
treatment Plant operating conditions, defined potential options to assure consistent compliance with
discharge limits, and selected the most appropriate option for further evaluation.
2) MILESTONE 2 - COMPLETION OF DESIGN AND OTHER PERMITTING —January 1, 2013
Permittee conducted detail engineering evaluation and engineering design of the selected option. If
selected option requires any wastewater plant upgrades then Permittee to seek State approval for
implementation.
3) MILESTONE 3 - COMPLETION AND START UP — IN COMPLIANCE — January 1, 2014
Permittee procured equipment for needed upgrades, installed equipment, completed start-up and
debugging of new equipment/process. Acrolein limits are enforced.
Reports to include owner's name, NPDES permit number, and Permittee contact person. Reports to be remitted
to:
(1) NCDENR
Ron Berry
1617 Mail Service Center
Raleigh, NC 27699-1617
(2) NCDENR/Surface Water Protection
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Part I, Page 19 of 19

DuPont Kinston Plant
Hwy. 11 North
PO Box 800
Kinston, NC 28502.0800
October 31, 2011
CERTIFIED MAIL: 7009-0820-0001-9460-2161
RETURN RECEIPT REQUESTED
Mr. Ron Berry
NCDENR
Division of Water Quality, Eastern NPDES
1617 Mail Service Center Raleigh, NC 27699-1617
Re: Acrolein Compliance Schedule: NPDES Permit NC0003760
Dear Mr. Berry:
I requested a modified compliance schedule on 8/11/2011 which extended the first 2 milestones
of the NPDES Acrolein Compliance Plan by 4 months. After reviewing the timing of data
analysis and the potential of a modification to the permit, I would request that we extend the
milestone dates for all 3 milestones by 4 months. The new milestone dates be as follows:
Milestone 1 — Completion of the Evaluation process — April 1 2012
Milestone 2 — Completion of Design and Other Permitting - Jan 1, 2013
Milestone 3 — Completion and Start Up — Demonstrate Compliance — Jan 1, 2014.
Please let me know if this is an acceptable modification to the Acrolein Compliance Schedule as
listed in the Kinston Site NPDES Permit Modification dated November 12, 2010. If you have
any questions or comments concerning this request, please feel free to contact me at 252-522-
6538. I can also be reached by e-mail at [e-mail]
Serely,
Alex Torres
Environmental and Safety Manager
DuPont Kinston Plant
kr_aowE
i NOV 0 2 2011
DENR-WATER QUALITY
POINT SOURCE BRANCH
E.I. du Pont de Nemours and Company

NPDES Acrolein compliance Plan
From: Alex Torres [[e-mail]]
Sent: Friday, October 28, 2011 9:55 AM
To: Berry, Ron
Subject: NPDES Acrolein compliance Plan
Attachments: Acrolein Compliance.jpg
Mr Berry,
I requested a modified compliance schedule (see below) back on 8/11/2011 which
extended the first 2 milestones of the NPDES Acrolein compliance Plan by 4 months.
After reviewing the timing of data analysis and the potential of a modification to
the
permit, I would request that we extend the milestone dates for all 3 milestones by 4
months rather than just the first two. A written request will follow in the mail.
If there are questions, please contact me on 252-522-6538 or by email.
Thanks
Alex Torres
DuPont Kinston Site
SHE Manager
This communication is for use by the intended recipient and contains
information that may be Privileged,confidential or copyrighted under
in
tended law. If you are not the recipient, you are hereby
formally notified that any use, copying or distribution of this e-mail,
in whole or in part, is strictly prohibited. Please notify the sender by
return e-mail and delete this e-mail from your system. unless explicitly
and conspicuously designated as "E-contract Intended", this e-mail does
not constitute a contract offer, a contract amendment, or an acceptance
of a contract offer. This e-mail does not constitute a consent to the
use of sender's contact information for direct marketing purposes or for
transfers of data to third parties.
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http://www.Dupont.com/corp/email_disclaimer.html
Page 1

I k J
Berry, Ron
From: Berry, Ron
Sent: Wednesday, October 05, 2011 11:05 AM
To: 'Alex Torres'
Cc: Hodge, Al; Bullock, Robert
Subject: RE: Kinston Compounding Project
Alex,
Your summary covers our discussions and I am in agreement. One point of clarity, the necessary treatment process, or
no additional treatment process, as determined by DuPont must be communicated and documented to the Division
including any performance criteria used. A description of the new treatment process, list of new treatment equipment
components, and confirmation of new treatment start up must be provided to the Division, and will be a condition in
the modified permit. A technical correction to the permit's supplemental page may be issued after confirmation of the
addition of new treatment components.
Ron
Ron Berry [e-mail]
Engineer I
DWQ/Point Source/NPDES Complex Permitting Unit
NCDENR
Phone: [phone]
Fax: [phone]
Office: Archdale Building Room 925N
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or other regulation.
From: Alex Torres Finailto:[e-mail]
Sent: Wednesday, October 05, 2011 9:20 AM
To: Berry, Ron
Cc: Bharat 0 Desai
Subject: Kinston Compounding Project
Ron,
Below is summary of our discussion...Iet me know if I accurately captured actions/timing required by
the Kinston Site to meet current/future regulatory requirements and if there are any corrections
needed. After your input I will send to project team with you on the cc list.
Thanks
Alex
Compounding Project Zinc containing Process Water:
Ron,
Bharat Desai (DuPont Engineering) and I discussed with you the following during the conference call on October 4, 2011
related to management of zinc containing process wastewater from the Compounding Project:
1

1. At present DuPont does not have good basic data on the process wastewater that will be generated from the
Compounding Project (flow and zinc level), so it will be difficult to design and build a treatment system for zinc
removal.
2. DuPont plans to run Compounding Test Campaign for approximately 40 days in 2012. We plan to store on -site
zinc containing process wastewater generated during this campaign, and define basic data (flow and zinc level)
for zinc removal technology selection, designing and building a treatment facility.
3. DuPont will provide a representative sample of the process wastewater to a vendor for lab scale treatability study
to determine treated effluent zinc level achievable through available technology.
4. DuPont will review basic data and vendor lab scale treatability data with you to determine pathforward for
permitting discharge of the treated stream.
5. If permit modification is needed as currently anticipated, DuPont will submit a permit modification application with
lab treatability data.
6. The State will review the application and treatability data, and determine if zinc discharge limit is warranted or not,
and issue a modified permit with zinc discharge limit if needed. It is anticipated it will take about 90 days to modify
the permit after application is submitted.
7. Once the permit is modified, it will be up to DuPont how to comply with it.
8. Once the permit is issued, DuPont will determine what is needed to comply with it and install a treatment facility if
one is needed.
9. The stored material will be processed as required to assure compliance with the modified permit.
10. Since the zinc containing stream that will be generated is not listed in the metal bearing streams list published
under the US EPA OCPSF effluent guidelines, metals limits applicable to OCPSF stream will not apply to the
Compounding stream.
11. The State will determine if toxicity testing is needed or not and may ask DuPont to conduct such a test prior to
issuing modified permit.
•
This communication is for use by the intended recipient and contains
information that may be Privileged, confidential or copyrighted under
applicable law. If you are not the intended recipient, you are hereby
formally notified that any use, copying or distribution of this e-mail,
in whole or in part, is strictly prohibited. Please notify the sender by
return e-mail and delete this e-mail from your system. Unless explicitly
and conspicuously designated as "E-Contract Intended", this e-mail does
not constitute a contract offer, a contract amendment, or an acceptance
of a contract offer. This e-mail does not constitute a consent to the
use of sender's contact information for direct marketing purposes or for
transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
http://www.DuPont.com/core/email.._disclaimer.html
2

Berry, Ron
From: Berry, Ron
Sent: Wednesday, October 05, 2011 8:46 AM
To: Hodge, AI; Bullock, Robert
Subject: Update on DuPont Kinston
FYI
Al & Robbie,
Got a phone call from Alex and Bharat, DuPont Kinston, to discuss testing of a new proposed zinc -based process. The
process would increase the zinc concentration in Kinston waste water. We had discussed this proposed process change
previously, and told DuPont any change to the wastewater characteristics would require a NPDES permit
modification/review.
DuPont asked about conducting a 30 day test trial and storing the 300,000 — 400,000 waste water produced on site
until it could be properly treated and/or disposed of. The reasons given for the trial were to better define the waste
water volume, to define the waste water characteristics, and to further refine the treatment process needed. My answer
was the Division had no problem with this test because this in no way impacted the NPDES permit conditions or resulted
in a discharge to the surface water.
The permit modification application would be submitted once the information from the test is evaluated. DuPont
understands they have to have the modified permit before treating the new waste water. Best guess given on timetable
to issue a modified permit was 90 days from acceptance of the application assuming no complications. Under the new
state statues DuPont will not be required to obtain an AtC. A toxicity test may be requested by the Division on the
proposed new effluent as part of the permit modification review. DuPont would need to demonstrate they had the
capability to meet any permit conditions.
Told DuPont the Division cannot issue a permit to any facility that cannot met the permit conditions. I asked DuPont did
this new process fall under the federal guidelines for listed process with metal -based waste streams, the answer was no.
You have any questions or comments please let me know.
On another note, I am planning on issuing the requested minor permit modification (no public notice just a amended
page) to move the first two milestones forward 4 months in the existing DuPont permit in October. If there is a concern
we need to discuss in the immediate future.
Thanks,
Ron
Ron Berry [e-mail]
Engineer I
DWQ/Point Source/NPDES Complex Permitting Unit
NCDENR
Phone: [phone]
Fax: [phone]
Office: Archdale Building Room 925N
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or other regulation.
1

DuPont Kinston Plant
Hwy. 11 North
PO Box 800
Kinston, NC 28502-0800
September 10, 2011
CERTIFIED MAIL: 7009-0080-0002-4022-2985
RETURN RECEIPT REQUESTED
Company Confidential
Mr. Ron Berry
NCDENR
Division of Water Quality, Eastern NPDES
1617 Mail Service Center Raleigh, NC 27699-1617
Re: Process Modification of NPDES Permit NC0003760
Dear Mr. Berry:
The DuPont Kinston Manufacturing Site is modifying the existing 3G2 process to allow the
addition of additives to the basic Sorona Polymer Process. One of the process steps will result in
a waste water stream that can contain approximately 75 mg/L zinc at a flow of 10 gallons per
min (gpm) based on limited lab study. The actual flow rate and zinc concentration will be
known only after the process operations starts. We plan to treat this stream prior to discharge to
the Kinston Waste Treatment Plant (WTP) to lower the zinc level to approximately 1-2 mg/L at
10 gpm. This material, Phosphinic acid, P,P-diethyl-, zinc salt (2:1): PMN Number P-05-11
(CAS No. 284685-45-6) falls under the "Significant New Use Rule" (SNUR), 40 CFR 721. The
chemical formula is C4H1102P.1/2 Zn. Will the use of this particular material require significant
modification to our existing NPDES permit and with continued monitoring for zinc at the
existing frequency or will the frequency be modified?
If you have any questions or comments concerning this request, please feel free to contact me at
252-522-6538. I can also be reached by e-mail at [e-mail]
Sinrely,
ex Tbfres
Environmental and Safety Manager
DuPont Kinston Plant
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SEP 15 2011
DENR-VGA'{ER QUALITY
POINT SOURCE BRANCH
E.I. du Pont de Nemours and Company

Berry, Ron
From: Berry, Ron
Sent: Friday, September 09, 2011 10:51 AM
To: 'Alex Torres'
Subject: Follow up to phone conversation - revised
Alex,
After our phone discussion, I conducted a more detailed review of the statutes dealing with a permit modification, and
conducted an initial review of the 40CFR721 standards. I have the following comments:
1) The introduction of a new chemical substances into an effluent is deemed a change in the effluent
characteristics. By statutes this requires a major permit modification which requires submittal of a modification
application and fee, Division review, issuance of a draft permit for 30 day public comment, response to
comments, and Issuance of a final permit.
2) The impact to your current permit zinc requirements, and whether the zinc change itself requires a major permit
modification is unknown at this time. As we discussed the Division requires a formal letter with details on the
anticipated zinc impact.
3) The impact of the new chemical compound to your permit is unknown but will be determined after we review
your formal request and details. Again, in your formal letter provide as much details as you can on the impact of
the new chemical on the discharge effluent.
4) Upon receipt of your request with the chemical nomenclature we will do a more thorough review of 40CFR721.
However, be advised that this federal standard describe several items that DuPont needs to access and
determine work place safety, notification of persons who may come in contact with this substance, etc.. The
Division focus is introduction of a new chemical into a discharge to surface waters. I recommend you include a
MSDS for the new chemical compound with the formal request for reference. After review of your request, you
will be notified if more information or additional testing is required.
5) Based on the above I do not think a 2 week turnaround on your request is feasible. If a major permit
modification is required then we are looking at a minimum of 70-90 days after receipt of the modification
application assuming no additional items have to be addressed before a draft permit is issued for comment.
Hope this information is helpful.
Ron
Ron Berry [e-mail]
Engineer I
DWQ/Point Source/NPDES Complex Permitting Unit
NCDENR
Phone: [phone]
Fax: [phone]
Office: Archdale Building Room 925N
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or other regulation.
f 22(, (o t3 S
Riaa,sz 1-1) 2/ ° (604) (±) H) ) 2-
1

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(a) This part identifies uses of chemical substances, except for mic,,,.,iganisms regulated under part 725 of this chapter, which EPA has
determined are significant new uses under the authority of section 5(a)(2) of the Toxic Substances Control Act. In addition, it specifies procedures
for manufacturers, importers, and processors to report on those significant new uses. This subpart A contains general provisions applicable to this
part. subpart B of this part identifies generic requirements for certain significant new uses cross referenced in specific provisions of subpart E of
this part. subpart C of this part identifies generic reporting requirements for certain significant new uses cross referenced in specific provisions of
subpart E of this part. subpart E of this part identifies chemical substances and their significant new uses.
(b) This subpart A contains provisions governing submission and review of notices for the chemical substances and significant new uses identified
in subpart E of this part. The provisions of this subpart A apply to the chemical substances and significant new uses identified in subpart E of this
part, except to the extent that they are specifically modified or supplanted by specific requirements in subpart E of this part. In the event of a
conflict between the provisions of this subpart A and the provisions of subpart E of this part, the provisions of subpart E of this part shall govern.
(c) The provisions of part 720 of this chapter apply to this part 721. For purposes of this part 721, wherever the phrase "new chemical substance"
appears in part 720 of this chapter, it shall mean the chemical substance subject to this part 721. In the event of a conflict between the provisions
of part 720 of this chapter and the provisions of this part 721, the provisions of this part 721 shall govern.
[53 FR 28358, July 27, 1988, as amended at 62 FR 17932, Apr. 11, 1997]
P

§ 721.10135 Phosphinic acid, P,P-diethyl-, zinc salt (2:1)
(a) Chemical substance and significant new uses subject to reporting . (1) The chemical
substance identified as phosphinic acid, P,P-diethyl-, zinc salt (2:1) (PMN P-05-11; CAS No.
284685-45-6) is subject to reporting under this section for the significant new uses described in
paragraph (a)(2) of this section.
(2) The significant new uses are:
(i) Release to water . Requirements as specified in §721.90 (a)(4), (b)(4), and (c)(4) (N=12).
(ii) [Reserved]
(b) Specific requirements . The provisions of subpart A of this part apply to this section except
as modified by this paragraph.
(1) Recordkeeping . Recordkeeping requirements as specified in §721.125 (a), (b), (c), and (k)
are applicable to manufacturers, importers, and processors of this substance.
(2) Limitations or revocation of certain notification requirements . The provisions of §721.185
apply to this section.
[74 FR 29994, June 24, 2009]

Electronic Code of Federal Regulations: Page 1 of 2
•
§ 721.90 Release to water.
Whenever a substance is identified in subpart E of this part as being subject to this section, a significant
new use of the substance is:
(a) Any predictable or purposeful release of a manufacturing stream associated with any use of the
substance, from any site:
(1) Into the waters of the United States.
(2) Into the waters of the United States without application of one or more of the following treatment
technologies as specified in subpart E of this part either by the discharger or, in the case of a release
through publicly -owned treatment works, by a combination of treatment by the discharger and the
publicly -owned treatment works:
(i) Chemical precipitation and settling.
(ii) Biological treatment (activated sludge or equivalent) plus clarification.
(iii) Steam stripping.
(iv) Resin or activated carbon adsorption.
(v) Chemical destruction or conversion.
(vi) Primary wastewater treatment.
(3) Into the waters of the United States without primary wastewater treatment, and secondary
wastewater treatment as defined in 40 CFR part 133.
(4) Into the waters of the United States if the quotient from the following formula:
number of kilograms/day/site released X 1000 = N parts per billion
receiving stream flow (million liters/dot
exceeds the level specified in subpart E of this part when calculated using the methods described in
§721.91. In lieu of calculating the above quotient, monitoring or altemative calculations may be used to
predict the surface water concentration which will result from the intended release of the substance, if
the monitoring procedures or calculations have been approved for such purpose by EPA. EPA will
review and act on written requests to approve monitoring procedures or alternative calculations within 90
days after such requests are received. EPA will inform submitters of the disposition of such requests in
writing, and will explain the reasons therefor when they are denied.
(b) Any predictable or purposeful release of a process stream containing the substance associated with
any use of the substance from any site:
(1) Into the waters of the United States.
(2) Into the waters of the United States without application of one or more of the following treatment
technologies as specified in subpart E of this part either by the discharger or, in the case of a release
through publicly -owned treatment works, by a combination of treatment by the discharger and the
publicly -owned treatment works:
(i) Chemical precipitation and settling.
(ii) Biological treatment (activated sludge or equivalent) plus clarification.
(iii) Steam stripping.
(iv) Resin or activated carbon adsorption.
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Electronic Code of Federal Regulations: . Page 2 of 2
•
(v) Chemical destruction or conversion.
(vi) Primary wastewater treatment.
(3) Into the waters of the United States without primary wastewater treatment, and secondary
wastewater treatment as defined in 40 CFR part 133.
(4) Into the waters of the United States if the quotient from the following formula:
romber of kilograms/day/site released x 1000 - N parts per billion
receiving stream flow (millionliters/day)
exceeds the level specified in subpart E of this part when calculated using the methods described in
§721.91. In lieu of calculating the above quotient, monitoring or alternative calculations may be used to
predict the surface water concentration which will result from the intended release of the substance, if
the monitoring procedures or calculations have been approved for such purpose by EPA. EPA will
review and act on written requests to approve monitoring procedures or alternative calculations within 90
days after such requests are received. EPA will inform submitters of the disposition of such requests in
writing, and will explain the reasons therefor when they are denied.
(c) Any predictable or purposeful release of a use stream containing the substance associated with any
use of the substance from any site:
(1) Into the waters of the United States.
(2) Into the waters of the United States without application of one or more of the following treatment
technologies as specified in subpart E of this part either by the discharger or, in the case of a release
through publicly -owned treatment works, by a combination of treatment by the discharger and the
publicly -owned treatment works:
(i) Chemical precipitation and settling.
(ii) Biological treatment (activated sludge or equivalent) plus clarification.
(iii) Steam stripping.
(iv) Resin or activated carbon adsorption.
(v) Chemical destruction or conversion.
(vi) Primary wastewater treatment.
(3) Into the waters of the United States without primary wastewater treatment, and secondary
wastewater treatment as defined in 40 CFR part 133.
(4) Into the waters of the United States if the quotient from:
rnumber of kilograms/day/site released
x1000 = N parts per billion
receiving stream flow (millionliters/day)
exceeds the level specified in subpart E of this part, when calculated using the methods described in
§721.91. In lieu of calculating the above quotient, however, monitoring or alternative calculations may be
used to predict the surface water concentration expected to result from intended release of the
substance, if the monitoring procedures or calculations have been approved for such purpose by EPA.
EPA will review and act on written requests to approve monitoring procedures or alternative calculations
within 90 days after such requests are received. EPA will inform submitters of the disposition of such
requests in writing, and will explain the reasons therefor when they are denied.
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Date: 9/21/11
pb: rdb
Note: Sheet is protected, only access to unlock cells is allowed (C3, H9, H11, 118)
STEP 1: Convert cfs to million liters per day (apply lowest 7Q10 flow)
1 cuft = 28.3168466 liters
1 day = 86400 seconds
283.1 cf/s x 28.3168466 liters/cf x 86400 s/day x million liters/1000000 liters = 692.6255 milion liters/day
7Q10s = 283.100 cfs
STEP 2: Define discharge flow and concentration of compound EOP
Ratio of compound to zinc salt is 2:1
Estimate of process flow stream is 10 gpm with zinc = 75 mg/L
Will add added zinc removal to 10 gpm stream to reduce zinc to 2 mg/L pror to discharge into existing treatment system
Non -zinc portion to pass through, total (2 x 75 mg/L) + 2 mg/L =
10.0 gpm
152.0000 mg/L
STEP 3: Calculate maximum kilogram per day of compound discharge EOP
1 Ib = 0.453592 kilogram
1 day = 1440 minutes
150 mg/L x 8.34 lb-L/mg-million gallons x 10 gallons/m x 1440 m/day x million gallons/1000000 gallons x 0.453592 kilogram/lb = 8.280137 kilograms
STEP 4: Determine parts per billion and significance per 40 CFR 721.90
number of kilograms/day released
receiving stream flow (million liters/day)
8.280137 kilograms/day x 1000 =
692.6255 million liters per day
IF N > 12
x 1000 = N parts per billion
12 pa , s per billion 47092194261)
ffi- +s i 3F.. tj
T>12,Not significant use of thissubstance

Berry, Ron
From: Berry, Ron
Sent: Wednesday, September 21, 2011 1:31 PM
To: 'Alex Torres'
Subject: Follow up information for the 40CFR 721 code
Alex,
Mr. Desai contacted me and provided the information I had requested in regards to Subpart E. As requested I left Mr.
Desai a voice message that I had completed the calculation described in 1). The items listed in this email are several
responses I received from EPA Region IV NPDES section in Atlanta. Also, for review is a summary of the significant use
calculation , I recommend any questions about reporting under 40CFR 721 be addressed by contacting the contact
information provided. Mr. Desai suggested I sent you this email and you would forward a copy to him.
1) Determination of significant surface discharge:
Use lowest stream flow 7Q10 flow which in your case is 7Q10 summer = 283.1 cubic feet per second
Convert stream flow to million liters/day
283.1 cfs x 28.3168466 liters/cf x 86400 s/day x 1/1000000 = 692.6255 million liters/dav
Process wastewater effluent flow contribution from new compound
10 gpm effluent, 150 mg/L non -zinc portion and 2 mg/L zinc salt portion (ratio of non -zinc to zinc 2:1, 75
mg/L is zinc level prior to new zinc removal treatment with reduction of zinc to 2 mg/L, non -zinc portion
passes through zinc removal)
Calculate maximum kilograms per day effluent discharge
(150 mg/L + 2 mg/L) x 8.34 lb-L/mg-MG x 10 g/m x 1440 m/day x 0.453592 kg/lb x 1 MG/1000000 g =
8.280137 kilograms/dav
Calculate of significance per 40 CFR 721.90 (4)(c) per 721.10135, N=12
8.280137 kilograms /dav x 1000 = 12 parts per billion (11.9547)
692.6255 liters/day
Calculated parts per billion is NOT greater than N so "this is not a significant use of this substance".
Note: If the flow contribution exceeds 10 GPM or the substance concentration exceeds 152 mg/L then the
calculated parts per million will exceed 12 and thus becomes "a significant use of this substance".
Again, I would refer you to the contact information listed below for meeting the reporting requirements.
Reponses (1) and (2) are from EPA Region IV on my inquiry about 40 CFR 721, for your review:
(1)
Part 721 are reporting/filing requirements under the Toxic Substances Control Act (TSCA).
Different statute than the Clean Water Act.
Questions about TSCA requirements can be sent to the TSCA hotline at:
tsca-hotlinetepa.gov
There is also information at:
http://www.epa.gov/opptintr/newchems/index.htm
(2)
Here is what I found on the Internet at this link.
http://www.epa.gov/oppt/newchems/pubs/snun.htm
I copied the major article here.
Submitting a Significant New Use Notice (SNUN)
1

Under section 5(a) of TSCA and 40 CFR part 721, if EPA promulgates a Significant New Use Rule
(SNUR), a manufacturer or processor wishing to engage in a designated significant new use
must submit a Significant New Use Notice (or "SNUN") to EPA at least 90 days before engaging
in the new use. In many cases, EPA will need to respond to a SNUN by amending the SNUR to
allow companies other than the SNUN submitter (such as the submitter's processor customers)
to engage in the newly approved use(s).
Note that before EPA amends the SNUR, even after a manufacturer submits a SNUN and the review
period expires, processors (and other
manufacturers) of the substance are still legally required to submit their own SNUN before
engaging in the significant new use. Therefore, potential SNUN submitters should be aware of
40 CFR 721.25(b), which authorizes joint SNUNs by two or more persons -- for example, a
manufacturer and several processors.
EPA recommends that submitters consult with the Agency prior to submitting a SNUN to discuss
what data may be useful in evaluating a significant new use. Discussions with the Agency
prior to submission can afford ample time to conduct any tests that might be helpful in
evaluating risks posed by the substance.
SNUNs are reported using the standard PMN form and are subject to a 90-day review process
similar to that for a PMN. When submitting a SNUN, the submitter should include a cover
letter that provides the CFR citation of the SNUR and identifies the specific significant new
use(s) for which the SNUN is being submitted.
If you submit a SNUN to EPA, you are required to use the electronic-PMN
("e-PMN") software as discussed in the "e-PMN" final rule (75 FR 773)
(PDF) (18 pp, 110K, about PDF). You must use the PMN module within the e-PMN software to
submit your SNUN. On page 1 of the PMN module, be sure to check the box stating the type of
notice you are submitting is a SNUN.
During the first year following the effective date of the final rule, SNUN submissions will
be permitted via Central Data Exchange (CDX), optical disc or paper. One year after the
rule's effective date, i.e., as of April 6, 2010, paper submissions will not be accepted. Two
years after the final rule's effective date, i.e., as of April 6, 2011, all submissions will
be required to be submitted electronically via CDX.
Refer to www.epa.gov/cdx, the CDX Registration Guide (PDF) (44 pp, 8.6MB, about PDF), or the
CDX Helpful Hints (PDF) (10 pp, 41K, about PDF
) for directions on how to register and submit notices via CDX.
Mail paper SNUNs to:
U.S. Environmental Protection Agency
OPPT Document Control Office (7407M)
1200 Pennsylvania Ave., NW
Washington, DC 20460
Hope this is helpful.
Ron
2

Calculation of significant use surface water discharge
Ron Berry [e-mail]
Engineer I
DWQ/Point Source/NPDES Complex Permitting Unit
NCDENR
Phone: [phone]
Fax: [phone]
Office: Archdale Building Room 925N
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or other regulation.
3

DuPont Kinston Plant
Hwy. 11 North
PO Box 800
Kinston, NC 28502-0800
August 11, 2011
CERTIFIED MAIL: 7009-0080-0002-4022-2978
RETURN RECEIPT REQUESTED
Mr. Ron Berry
NCDENR
Division of Water Quality, Eastern NPDES
1617 Mail Service Center Raleigh, NC 27699-1617
Re: Acrolein Compliance Schedule: NPDES Permit NC0003760
Dear Mr. Berry:
The DuPont Kinston Manufacturing Site has been testing several acrolein reduction
technologies/strategies as part of our evaluation process. Reducing acrolein in our wastewater
stream to the new lower level required by the permit of 0.126 ppm has proved a challenging task.
The issue appears to be a chemical equilibrium that we have not completely defined. In order to
better define potential options to assure consistent compliance with discharge limits and selecting
the most appropriate option for further evaluation we are asking that the initial Milestone date be
moved from December 1, 2011 to April 2, 2012. Milestone II would move to January 15, 2013.
The compliance date of Sept 1, 2013 would remain the same. Please let me know if this is an
acceptable adjustment to the compliance schedule.
If you have any questions or comments concerning this request, please feel free to contact me at
252-522-6538. I can also be reached by e-mail at [e-mail]
Sincerely,
ex Torres
Environmental and Safety Manager
DuPont Kinston Plant
AUG 1 7 2011
DENR-WATER QUALITY
POINT SOURCE BRANCH
E.I. du Pont de Nemours and Company