NC0003760_Wasteload Allocation_19901024

NPDES DOCUHENT !CANNING 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:
October 24, 1990
This document is printed on reuse paper - ignore a.1iy
content on the reirerse side

DIVISION OF ENVIRONMENTAL MANAGEMENT
MEMORANDUM
TO: Trevor Clements
FROM:
Ruth Swanek
October 24, 1990
SUBJECT: Meeting with E.I. DuPont - Kinston Plant
NPDES No. NC0003760
Lenoir County
Juan and I attended a meeting with E.I. DuPont today to dis-
cuss their draft NPDES permit. The following people attended the
meeting:
Name,
Juan Mangles
Ruth Swanek
Rosanne Barona
Jerry Bailey
Don Safrit
Jan Kneib
Dale Overcash
Dick Hargitt
Dick Schwer
Agency_
DEM/Tech Support
DEM/Tech Support
DEM/Permits
DuPont/Kinston
DEM/Permits
DuPont/Kinston
DEM/Permits
DuPont
DuPont
Phone
733-5083
733-5083
733-5083
522-6253
733-5083
522-6294
733-5083
522-6225
302/366-4257
The meeting began with an overview of DEM's basin management
approach. The DuPont representatives indicated that they believed
that it is the best way to perform wasteload allocations.
DuPont is objecting to its instream monitoring requirements.
The facility is currenteiy monitoring dissolved oxygen approximately
1 mile downstream'0.f."=its outfall. The draft permit requires them
to monitor temperature, DO, BOD5, conductivity, and pH during the
summer months at a point 3 miles downstream. There are many
obstructions in the Neuse River which makes it difficult to
maneuver in a boat. The downstream sampling point cannot be
accessed, and their employees must launch a boat at the plant and
travel an additional two miles from their current sampling point.
We explained that a sampling plan had been set up such that DuPont
and the two Kinston facilities were collecting samples at different
critical locations in the Neuse River. DuPont stated that we would
gain more information if one person/facility collected the infor-
mation on a given date. They are proposing to sample the entire
river from Falls Dam to Pamlico Sound one time per year in lieu of
weekly monitoring. We may be able to get them to collect long term
BOD samples during this monitoring run. We informed them that we
needed to investigate this proposal further and we would contact

them at a later date with more information. This may not be feas-
ible for this permit period, but DEM may want to consider some type
of schedule like this in its basin management plans. For example,
different major facilities may be able to do sampling runs during
different summer months. This may be able to be accompanied with
less frequent instream summer monitoring. If this sampling is not
feasible, we have informed DuPont that they will only have to
sample from June to September. In addition, we could drop their
BOD5 monitoring requirement since not much information is gained
from it. We need to investigate the possibility of moving the
monitoring site to the current location. You, Juan, and I should
meet to discuss this issue in the near future.
DuPont then discussed the use of their maximum monthly average
flow of 2.3 MGD instead of their long term average flow of 1.9 MGD
in determining the effluent guidelines limits. The facility will
submit more data to Permits, and they will further review it.
DuPont then requested that we give them credit for BOD in
their noncontact cooling water in order to raise the effluent gui-
deline limit. Don stated that if they discharged their cooling
water separately, they would not receive a BOD limit. The facility
agreed to this, and the proposed limit will remain in the permit.
DuPont wanted further information on why some of the OCPSF
parameters were water quality limited when there was no state
standard for the parameter. We informed them of the agreement
between EPA and DEM to use the federal criteria, but they would
like more background information concerning the agreement. They
believe that some of the federal criteria do not have a solid tech-
nical basis. We need to discuss this with you as soon as possible.
In addition, DuPont was informed that some of these water quality
limits may have been derived if a given parameter was a PAH since
there is a standard for PAH's. We need to inform them of any par-
ameters that are PAH's.
DuPont also did not like having NPDES limits for all of the
OCPSF guideline parameters since the organic constituents are not.
present in their waste. They believe that environmental groups may.
read their permit and infer that they are discharging all of these
compounds at permitted levels. They proposed using permit language
which prohibits the discharge of these organics and requires them
to monitor for them annually. This was done for DuPont's Niagara
Falls facility. Dale indicated that he would have to consult with
Region IV, but he did not think they would be agreeable. Having
concentrations below detection does not mean the substance is not
in the effluent although he believes that the process also indi-
cates that it is not.
DuPont then requested that the quarterly metals monitoring
requirement be dropped from the NPDES permit for outfalls 002 and
003. They provided us with monitoring information (attached).
Permits and Engineering indicated that the monitoring could be
dropped. I disagree since the discharges are into zero flow
streams, and some of the concentrations are near or exceed stan-

dards/action levels. We need to sit down with Don and Dale and
write a Division response.
The DuPont representatives then inquired about the turbidity
limits on outfalls 002 and 003. They indicated that it is very
rare that runoff from the parking lot would go to outfall 002 due
to the topography of the land. This would occur only during hard
downpours and not during an average rainstorm. Therefore, the
turbidity limit can be dropped from outfall 003. Outfall 002
receives storm water runoff from a courtyard area which has gravel
areas. Don suggested that DuPont begin implementing best
management practices. Since the regional office recommended the
turbidity limits, Juan will contact them and see if BMPs could be
substituted for an NPDES limit.
Let's set up a meeting to discuss the unresolved issues. Let
me know if you have any questions.

MEMORANDUM
To: Trevor Clements
Juan Mangles
Roger Thorpe
Dick Denton
From: Rosanne Barona fit_
Subject: NC0003760
E. I. Dupont - Kinston Facility
•
October 11, 1990
OCT 1 1 1990
TECHhICALRigT BRANCH
1
E. I. Dupont has requested a meeting to discuss their comments on the draft permit (see
attached). A meeting has been set up on October 24, 1990 at 10:00 am in the 6th floor conference
room. Please let me know if you will attend the meeting.

COMMENTS ON DRAFT NPDES PERMIT NO. NC0003760
E. I. DU PONT, KINSTON MANUFACTURING FACILITY
PERMIT COVER SHEET - Duration of Permit - 80'1 Ptah
The proposed permit should be issued for five-year duration.
The draft indicates that the permit would expire on January 31, 1994. This
would mean a permit duration of less than 3 1/2 years by the time the final
permit is issued later this year. Our existing permit was issued for 5 years.
The proposed permit should also be issued for a 5-years period from its
effective date.
— OUTFALL 001 EFFLUENT LIMITATIONS - iD Or.
BOD5 and TSS Monthly Average Discharge Limits
The monthly average discharge limits for BOD5 and TSS should be based on the
maximum monthly average flow rate and should include an allowance for the BOD5
and TSS conveyed by the nonprocess wastewater through the treatment facilities.
The information for applying these factors contained in Attachment II of our
permit renewal letter (October 26, 1989 from C. E. Nix, Du Pont to 1 Overcash,
DEM) enabled us to calculate monthly average limits of 450 and 780 t• for BOD5
and TSS respectively.
The DEM used the long-term average flow rate for process wastewater of 1.931
MGD shown in the water flow schematic attached to the discharge permit
application as the basis for calculating the BOD5 and TSS monthly average
limits. However, permit limits for Outfall 001 should incorporate consider-
ation of both concentration and flow variability. This discharge flow varies
from month to month and our evaluation, as described in Attachment II, indi-
cates that the maximum monthly average process wastewater flow rate would be
about 2.3 MGD.
The development of the OCPSF guidelines did not address variability of flow nor
do the concentration guidelines implicitly incorporate flow variability.
However, in the memorandum NPDES Permitting Strategy for OCPSF Industry Direct
Dischargers (February 28, 1989 from J.R. Elder, EPA OWEP to NPDES Delegated
State Directors) the EPA advises permit writers that "[i]n situations where
flow varies significantly from month -to -month, use discretion to develop a
case -by -case determination". Furthermore in a previous October 12, 1988
memorandum to NPDES State Directors entitled Questions and Answers Regarding
the OCPSF Effluent Limitations Guidelines, Elder stated that, "[i]t would be
within the Permit Writer's discretion to consider various data in determining a
proper long-term average flow for each facility, e.g., the highest monthly
average flow during the past twelve (12) months or the highest yearly mean of
the twelve monthly average flows during the past five (5) years". Therefore
the maximum monthly process wastewater flow of 2.3 MGD should be used as the
basis for calculating monthly average BOD5 and TSS limits.
1
RECEIVED S.
JUL :i 0 )yyli
PERMITS & E,NG►NEERINr,

2
The February 28 OCPSF permitting strategy memorandum also provides a basis for
allocating BOD5 and TSS loadings to nonprocess wastewater. Step A-5 in
Attachment C "Compliance Assessment Procedure for OCPSF Directed Discharges"
states:
"Determine if there is any non-OCPSF process wastewater or
nonprocess wastewater discharging to the same outfall and
contains detectable BOD5 or TSS. If yes, enter its long-term
average flow and assign allowable concentrations based on the
permit writer's BPJ."
The proposed permit appropriately does include allowances of 30 mg/L BOD5 and
30 mg/L TSS for the 0.1 MGD sanitary wastewater flow through the treatment
system. The remaining nonprocess wastewater flow of 0.4 MGD is composed mostly
of noncontact cooling water but has not been assigned BOD5 and TSS
concentration levels by the DEM. In Du Pont's application letter we had
proposed assigning an allowable concentration of 10 mg/L for both BOD5 and TSS
to this flow based on the anticipated incremental loading for this wastewater
through the treatment system.
—.Weekly River Sampling for Dissolved Oxygen, Conductivity, BOD5, pH and
Temperature April through October
River sampling for these parameters will provide no correlation with effluent
quality and should not be included as a discharge permit monitoring
requirement. River sampling constitutes a serious safety hazard that we want
to eliminate as a condition of our permit.
The previous permit had included only dissolved oxygen sampling in the river.
During 5 years of data collection we have seen no relationship between outfall
water quality and river water quality even for low flow and low DO conditions
in the river during the summer. These data have shown only the expected
seasonal changes in the level of D0. This result is to be expected since the
flow from Outfall 001 is only about 2% of the Neuse River 7Q10 low flow of 150
MGD. Moreover, Outfall 001 discharges water that has undergone a high degree
of biological treatment to prevent any impact on the river.
To reiterate our position from the October 26 application letter, we remain
concerned about the inherent safety of the operations required to launch a boat
into the Neuse River in all kinds of weather, collect samples, and return the
boat to storage. This concern is further heightened by the proposed
requirement to collect samples 3 miles downstream instead of one mile as
presently done.

- 3
Effluent Priority Pollutant Limitations
Effluent limitations on the BAT priority pollutants should not be included in
the permit since the manufacturing facilities neither use nor generate these in
the process. Annual monitoring should be conducted instead.
Priority pollutant analyses of 5 0utfall 001 samples taken in 1988 that were
submitted with the discharge permit application showed that bis (2-ethylhexyl)
phthalate was the only BAT organic priority pollutant found and it is believed
that this is the result of a sampling or analytical artifact . The
concentration of bis (2-ethylhexyl) phthalate was substantially less than the
effluent guidelines limit. These data support the conclusion that organic
priority pollutants are not handled at the Kinston Plant and we know of no way
that they could be produced in the process operations. Very low concentrations
of chromium, copper, nickel, lead and zinc were detected at levels that are
orders of magnitude less than the effluent guideline limits for these metals.
These sampling results indicate that there is no need for the proposed effluent
limitations on 63 priority pollutants with a requirement for quarterly
measurement. We propose annual monitoring in conjunction with the permit
requirement for an annual pollutant analysis for Outfall 001.
Despite the fact that these 63 parameters have been listed because of OCPSF
effluent guidelines BAT requirements, 18 of the parameters have been given an
even lower limit and are described by the draft fact sheet as being "water
quality limited". No basis is given for this determination. To our knowledge,
the Neuse River has not been designated as a water quality limited stream for
any of these parameters, and the state surface water regulations list numerical
water quality standards for only total chromium and cyanide and action levels
(not standards) for copper and zinc. However, none of the 14 "water quality
limited" organic compounds are addressed in the standards for Class C waters.
We request that the DEM provide a detailed explanation of the basis for the
limits assigned these parameters.
0f particular concern is the fact that several of these parameters are likely
not to be measurable by GC/MS, because the effluent limits have been set so
low. Hexachlorobenzene (HCB) has a proposed limit of 0.003 lbs/day monthly
average which equates to a 0.14 ug/L concentration at an average 001 flow rate
of 2.5 MGD. The lowest method detection limit (MDL) reported from the 1988
sampling program was 7 ug/L. Three other samples were reported with an MDL of
9 ug/L for HCB. Twelve other parameters (acenaphthene, naphthalene,
benzo(a)anthracene, benzo(a)pyrene, 3,4-benzofluoranthene,benzo(k)fluoranthene,
crysene, acenaphthylene, anthracene, fluorine,phenanthrene, and pyrene) have
proposed limits of 0.136 lbs/day monthly average which equates to 6 ug/L.

4
All these parameters were reported with the same MDL's as hexachlorobenzene,
which means that they likely will not be measurable by the standard GC/MS
analytical procedures. This would lead to either limits that are indeterminate
by standard methodology or the need to develop sophisticated and costly special
analytical techniques to measure extremely low levels of constituents which are
not present. Neither of these approaches is acceptable to Du Pont.
OUTFALL 002 AND 003 EFFLUENT LIMITATIONS
—Turbidity Limits
Turbidity should not be required for Outfall 002 since it is not elevated
except during stormwater runoff through the outfall ditch. The reason for
including this parameter is not clear. Normally this outfall receives only
noncontact cooling water and steam condensate resulting in very low turbidity.
Turbidity has no relationship with facility discharge water quality. The only
time that turbidity would be elevated is during a storm event when runoff is
discharged through the outfall ditch.
The requirement to measure and limit the increase of turbidity in the
"receiving waters" for Outfall 003 is also inappropriate and should be
eliminated.
Turbidity in this small tributary is not associated with discharge of
noncontact cooling water and steam condensate through Outfall 003 since this
discharge is low in turbidity. The purpose and applicability for both of the
proposed turbidity limits is unclear.
Metals and Cyanide Quarterly Monitoring The proposal to monitor 10 metals and
cyanide in both Outfalls 002 and 003 quarterly is excessive and should be
dropped.
The proposed permit for both Outfalls 002 and 003 includes quarterly monitoring
on 10 metals plus cyanide. Yet none of these constituents is used in water
treatment or present in the discharge other than from incoming water or as
incidental corrosion products. Moreover, the proposed permit states that
"THERE SHALL BE NO CHROMIUM, ZINC OR COPPER ADDED TO THE COOLING WATER."
Analysis of Outfall 002 and 003 for these parameters indicates that they are at
very low levels. Under these circumstances, quarterly measurement is
excessive.

DIVISION OF ENVIRONMENTAL MANAGEMENT
August 28, 1990
MEMORANDUM
TO: Dale•dvercash
FROM: Juan C. Mangles
THROUGH: Carla Sanderson
Ruth Clark ►�C5
SUBJECT: Comments to Draft NPDES Permit
E.I. Du Pont de Nemours & Company
Kinston Plant
NPDES Permit No. NC0003760
Lenoir County
The Technical Support Branch has received the comments of the subject draft
NPDES permit dated July 27, 1990 to Rosanne Barona. Most of Du Pont's comments
concerning the draft pertain to matters related to the Permit & Engineering Unit.
However, there are few issues which relate to the analysis performed by this office
for which the following comments are offered:
Comment: Outfall 001 Effluent Limitations - Weekly River Sampling for Dissolved
Oxygen, Conductivity, BODS, pH and temperature April through October.
The required instream monitoring parameters are necessary to continuously
measure the impact of the discharge on the receiving waters regardless of previous
instream sampling results. The results of the instream monitoring will also help
DEM to allocate pollutant loads for all dischargers within the basin in 1994..
Du Pont's outfall 001 discharges into the Neuse River in a segment where
Kinston Peachtree and Kinston Northside WWTP's discharge approximately 6.0 miles
and 10.5 miles upstream from Du Pont's discharge respectively. In addition to
Kinston's and Du Pont's discharges, a major tributary of the Neuse, Contentnea
Creek, enters the river 5.0 miles below Du Pont's discharge. Contentnea Creek
receives effluent from the Metropolitan Sewer District WWTP and thus, also contrib-
utes to the D.O. sag in the Neuse River. All the NPDES permits for these facili-
ties will be due for renewal in 1994 according to the basinwide permitting
strategy. It is estimated that at that time we will be able to allocate pollutant
loads to all the aforementioned discharges within the basinwide context.
Therefore, the Technical Support Branch has established an instream self -
monitoring program for all the facilities discharging into this segment of the
Neuse River. The data collected will not only provide continuous monitoring of the
system but will also be used in upcoming modeling analyses of the Neuse River
basin.
In order to alleviate the hazards associated with the use of a boat during
high flow conditions, the instream monitoring requirements may be reduced to June
through September.

Comment!: Outfall 001 Effluent Limitations - Effluent Priority Pollutant Limita-
tions
Effluent guideline BAT requirements are compared with the allowable concen-
trations based on North Carolina water quality standards, effluent flow and 7Q10
stream flow (i.e. conservation of mass theory) in order to protect the water
quality standards instream. DEM standard operational procedures dictate that the
more stringent concentration will be the limit assigned to the NPDES permit. The
effluent limitation is then defined as "effluent limited" when an effluent guide-
line BAT requirement is assigned, and "water quality limited" when an effluent
limitation based on "the conservation of mass theory" is assigned.
In those cases where water quality standards have not been promulgated in
North Carolina for a particular pollutant, EPA Region IV has instructed DEM to
protect federal water quality criteria downstream from the discharge.
Please note that 2-Chlorophenol is water quality limited. The draft permit
indicates that this parameter is effluent limited. This is due to an oversight
when preparing the WLA. However, the recommended effluent limitation of 27.0 ug/1
for this parameter is correct.
Copper and Zinc are action levels, therefore, the permit limitations for
these parameters should be revised as follows:
Copper:
Zinc:
3,380 ug/1 (EL)
2,610 ug/1 (EL)
Comment:: Outfalls 002 and 003 Effluent Limitations - Turbidity Limits :,
It is the Technical Support's understanding that outfall 002 receives
storm water runoff from the courtyard area (i.e. dirt and grass area), and outfall
003 receives certain amounts of storm water runoff originating from a parking area.
Therefore, it is recommended that the turbidity requirements in both outfall 002
and outfall 003 be maintained in the NPDES permit.
Comment: Outfalls 002 and 003 Effluent Limitations - Metals and Cyanide Quarterly 1
Monitoring
According to the permit application, both outfall 002 and 003 discharge some
concentration of metals. It is believed that these concentrations are due to 1)
concentrated levels of background concentrations brought about by the evapora-
tion/condensation process carried out prior to discharge and 2) incidental corro-
sion products. However, since the presence of metals has been confirmed in the
submitted application material, DEM must maintain a long-term database of these
pollutants to ensure that the discharged metal concentrations will not violate
North Carolina standards and/or action levels.
Du Pont may request that the quarterly metal scan requirement be dropped from
the NPDES permit when the permit is due for renewal in 1994. This request may be
granted in the next permit renewal provided that the metal database indicates that
the North Carolina metal standards and action levels are protected in the receiving
surface waters under critical flow periods.
The cyanide monitoring requirement may be dropped from the current draft
permit. However, it is known that chromium, zinc, and/or copper are generally

4
added to cooling waters to control biological growth. Therefore, the condition in
the permit concerning the addition of these parameters to the cooling waters should
be maintained in the NPDES permit. Should Du Pont anticipate that these parameters
will be added to the cooling water, then Du Pont should notify DEM's Aquatic
Toxicology Unit for a toxicity assessment which may include permit limitations of
these parameters or a whole effluent toxicity test requirement.
If you need further clarification on this matter, please contact me at ext.
510.
cc: Roger Thorpe
Du Pont's WLA File
Central Files

a e
12003•1' REV.3.90
•
POtb
r4 V. Mt•lr
ESTABLISHED 1802
E. I. DU PONT DE NEMOURS & COMPANY
INCORPORATED
KINSTON PLANT
P.O. Box 800
KINSTON, NORTH CAROLINA 28502-0800
PHONE [phone]
FIBERS DEPARTMENT
July 27, 1990
Ms. Rosanne Barona, Environmental Engineer - NPDES Permits Group
Permits and Engineering Unit
Division of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Ms. Barona:
NPDES PERMIT NO. 0003760, E. I. DU PONT DE NEMOURS AND CO.,
KINSTON, LENOIR COUNTY,
OUTFALLS 001, 002, 003 RESPONSE TO DRAFT PERMIT
1
REcEvEr
D
19SU
PERMITS & ENGINEERING
We received the draft of NPDES Permit No. NC0003760 you sent to us
July 5, 1990 for the Du Pont Kinston facility and I want to thank you for the
opportunity to review and comment.
Attached are our comments for your consideration. In light of the
number and complexity of the issues that we have addressed in this letter, we
would like to request a meeting with DEM to enable further discussion as soon
as it is convenient prior to issuance of the public notice for the proposed
permit.
Please contact me [phone] if you have any questions regarding
these comments and proposed dates for our meeting.
/pwo
KNEIB1:52
Attachment
Sincerely,
Jan A. Knei
Senior Engineer
Environmental Affairs
BETTER THINGS FOR BETTER LIVING

COMMENTS ON DRAFT NPDES PERMIT NO. NC0003760
E. I. DU PONT, KINSTON MANUFACTURING FACILITY
PERMIT COVER SHEET - Duration of Permit
The proposed permit should be issued for five-year duration.
The draft indicates that the permit would expire on January 31, 1994. This
would mean a permit duration of less than 3 1/2 years by the time the final
�cv permit is issued later this year. Our existing permit was issued for 5 years.
The proposed permit should also be issued for a 5-years period from its
effective date.
OUTFALL 001 EFFLUENT LIMITATIONS
BOD5 and TSS Monthly Average Discharge Limits
The monthly average discharge limits for BOD5 and TSS should be based on the
maximum monthly average flow rate and should include an allowance for the BOD5
and TSS conveyed by the nonprocess wastewater through the treatment facilities.
Q The information for applying these factors contained in Attachment II of our
permit renewal letter (October 26, 1989 from C. E. Nix, Du Pont to D. Overcash,
DEM) enabled us to calculate monthly average limits of 450 and 780 ppd for BOD5
and TSS respectively.
The DEM used the long-term average flow rate for process wastewater o
MGD shown in the water flow schematic attached to the discharge permit
Li, application as the basis for calculating the BOD5 and TSS monthly average
limits. However, permit limits for Outfall 001 should incorporate consider-
ation of both concentration and flow variability. This discharge flow varies
from month to month and our evaluation, as described in Attachment II, indi-
cates that the maximum monthly average process wastewater flow rate would be
about 2.3 MGD.
The development of the OCPSF guidelines did not address variability of flow nor
do the concentration guidelines implicitly incorporate flow variability.
However, in the memorandum NPDES Permitting Strategy for OCPSF Industry Direct
CA, Dischargers (February 28, 1989 from J.R. Elder, EPA OWEP to NPDES Delegated
State Directors) the EPA advises permit writers that "[i]n situations where
flow varies significantly from month -to -month, use discretion to develop a
case -by -case determination". Furthermore in a previous October 12, 1988
memorandum to NPDES State Directors entitled Questions and Answers Regarding
the OCPSF Effluent Limitations Guidelines, Elder stated that, "[i]t would be
within the Permit Writer's discretion to consider various data in determining a
proper long-term average flow for each facility, e.g., the highest monthly
average flow during the past twelve (12) months or the highest yearly mean of
the twelve monthly average flows during the past five (5) years". Therefore
the maximum monthly process wastewater flow of 2.3 MGD should be used as the
basis for calculating monthly average BOD5 and TSS limits.
1
JUL.RECEIVED
30 1990
PERMITS & ENGINEERING

K
2
The February 28 OCPSF permitting strategy memorandum also provides a basis for
allocating BOD5 and TSS loadings to nonprocess wastewater. Step A-5 in
Attachment C "Compliance Assessment Procedure for OCPSF Directed Discharges"
states:
"Determine if there is any non-OCPSF process wastewater or
nonprocess wastewater discharging to the same outfall and
contains detectable BOD5 or TSS. If yes, enter its long-term
average flow and assign allowable concentrations based on the
permit writer's BPJ."
The proposed permit appropriately does include allowances of 30 mg/L BOD5 and
30 mg/L TSS for the 0.1 MGD sanitary wastewater flow through the treatment
system. The remaining nonprocess wastewater flow of 0.4 MGD is composed mostly
of noncontact cooling water but has not been assigned BOD5 and TSS
concentration levels by the DEM. In Du Pont's application letter we had
proposed assigning an allowable concentration of 10 mg/L for both BOD5 and TSS
to this flow based on the anticipated incremental loading for this wastewater
through the treatment system.
Weekly River Sampling for Dissolved Oxygen, Conductivity, BOD5, pH and
Temperature April through October
River sampling for these parameters will provide no correlat,iwn with effluent
uaq 1Tty and should not be included as --a- discharge permit monitoring
requirement. River sampling constitutes a serious safety hazard that we want
to eliminate as a condition of our permit.
The previous permit had included only dissolved oxygen sampling in the river.
During 5 years of data collection we have seen no relationship between outfall
water quality and river water quality even for low flow and low D0 conditions
in the river during the summer. These data have shown only the expected
seasonal changes in the level of DO. This result is to be expected since the
flow from Outfall 001 is only about 2% of the Neuse River 7Q10 low flow of 150
MGD. Moreover, Outfall 001 discharges water that has undergone a high degree
of biological treatment to prevent any impact on the river.
To reiterate our position from the October 26 application letter, we remain
concerned about the inherent safety of the operations required to launch a boat
into the Neuse River in all kinds of weather, collect samples, and return the
boat to storage. This concern is further heightened by the proposed
requirement to collect samples 3 miles downstream instead of one mile as
presently done.

-3
Effluent Priority Pollutant Limitations
Effluent limitations on the BAT priority pollutants should not be included in
the permit since the manufacturing facilities neither use nor generate these in
the process. Annual monitoring should be conducted instead.
Priority pollutant analyses of 5 Outfall 001 samples taken in 1988 that were
submitted with the discharge permit application showed that bis (2-ethylhexyl)
phthalate was the only BAT organic priority pollutant found and it is believed
that this is the result of a sampling or analytical artifact . The
concentration of bis (2-ethylhexyl) phthalate was substantially less than the
effluent guidelines limit. These data support the conclusion that organic
priority pollutants are not handled at the Kinston Plant and we know of no way
that they could be produced in the process operations. Very low concentrations
of chromium, copper, nickel, lead and zinc were detected at levels that are
orders of magnitude less than the effluent guideline limits for these metals.
These sampling results indicate that there is no need for the proposed effluent
limitations on 63 priority pollutants with a requirement for quarterly
measurement. We propose annual monitoring in conjunction with the permit
requirement for an annual pollutant analysis for Outfall 001.
Despite the fact that these 63 parameters have been listed because of OCPSF
effluent guidelines BAT requirements, 18 of the parameters have been given an
even lower limit and are described by the draft fact sheet as being "water
quality limited". No basis is given for this determination. To our knowledge,
the Neuse River has not been designated as a water quality limited stream for
any of these parameters, and the state surface water regulations list numerical
water quality standards for only total chromium and cyanide and action levels
(not standards) for copper and zinc. However,none of the 14 "water quality
limited" organic compounds are addressed in the standards for Class C waters.
We request that the DEM provide a detailed explanation of the basis for the
limits assigned these parameters.
0f particular concern is the fact that several of these parameters are likely
not to be measurable by GC/MS, because the effluent limits have been set so
k-,, low. Hexachlorobenzene (HCB) has a proposed limit of 0.003 lbs/day monthly
N. average which equates to a 0.14 ug/L concentration at an average 001 flow rate
of 2.5 MGD. The lowest method detection limit (MDL) reported from the 1988
sampling program was 7 ug/L. Three other samples were reported with an MDL of
9 ug/L for HCB. Twelve other parameters (acenaphthene, naphthalene,
benzo(a)anthracene, benzo(a)pyrene, 3,4-benzofluoranthene,benzo(k)fluoranthene,
crysene, acenaphthylene, anthracene, fluorine,phenanthrene, and pyrene) have
proposed limits of 0.136 lbs/day monthly average which equates to 6 ug/L.

4
All these parameters were reported with the same MDL's as hexachlorobenzene,
cv which means that they likely will not be measurable by the standard GC/MS
analytical procedures. This would lead to either limits that are indeterminate
by standard methodology or the need to develop sophisticated and costly special
analytical techniques to measure extremely low levels of constituents which are
not present. Neither of these approaches is acceptable to Du Pont.
OUTFALL 002 AND 003 EFFLUENT LIMITATIONS
Turbidity Limits
Turbidity should not be required for Outfall 002 since it is not elevated
except during stormwater runoff through the outfall ditch. The reason for
including this parameter is not clear. Normally this outfall receives only
noncontact cooling water and steam condensate resulting in very low turbidity.
Turbidity has no relationship with facility discharge water quality. The only
time that turbidity would be elevated is during a storm event when runoff is
discharged through the outfall ditch.
The requirement to measure and limit the increase of turbidity in the
receiving waters" for Outfall 003 is also inappropriate and should be
eliminated.
Turbidity in this small tributary is not associated with discharge of
noncontact cooling water and steam condensate through Outfall 003 since this
discharge is low in turbidity. The purpose and applicability for both of the
proposed turbidity limits is unclear.
IMetals and Cyanide Quarterly Monitoring The proposal to monitor 10 metals and
\ cyanide in both Outfalls 002 and 003 quarterly is excessive and should be
dropped.
The proposed permit for both Outfalls 002 and 003 includes quarterly monitoring
on 10 metals plus cyanide. Yet none of these constituents is used in water
treatment or present in the discharge other than from incoming water or as
incidental corrosion products. Moreover, the proposed permit states that
"THERE SHALL BE NO CHROMIUM, ZINC OR COPPER ADDED TO THE COOLING WATER."
Analysis of Outfall 002 and 003 for these parameters indicates that they are at
very low levels. Under these circumstances, quarterly measurement is
excessive.

l
RATIONALE FOR BASIN MANAGEMENT OF OXYGEN -CONSUMING WASTEWATER
DISCHARGES IN THE NEUSE RIVER BASIN
Technical Support Branch - July 1990
Background
Public concern regarding eutrophication and low dissolved oxygen (DO)
levels in the lower Neuse River basin resulted in the Division of Environmental
Management (DEM) taking a comprehensive, basinwide approach to these issues.
In January, 1988, the EMC formally classified the lower Neuse River as NSW and
implemented a basinwide nutrient control strategy. Furthermore, ambient DO
concentrations collected by DEM (Fig. 1) during summer months between 1983-1987
demonstrated a strong downward sloping gradient with standards' violations
frequently occurring in the lower portion of the river. Therefore, DEM has
embarked upon a basinwide modeling effort to establish an appropriate wasteload
allocation strategy.
Model Development
Phase 1: Falls Dam to Smithfield
In 1987, a QUAL2E model of the Neuse from Falls Dam to Smithfield was
developed. Field data indicated DO sags above Milburnie Dam and below Raleigh
not captured in ambient monitoring. Model predictions (Fig. 2) match observed
concentrations at low flow. The model results were used to develop equitable
wasteload allocations for the major dischargers in this segment of the river.
Phase 2: Streets Ferry to New Bern
An estuary model was developed in 1988 focusing on Weyerhauser's New Bern
Mill discharge. The model predicts DO sags in the estuary which match observed
levels. Weyerhauser's self -monitoring data indicate that more than 50 percent
of the DO concentrations observed during the summer months between 1982 and
1987 violated the state standard at three sampling locations: at the confluence
of Swift Creek, at the Narrows, and near the wildlife landing (Fig 3). As a
result of the modeling, Weyerhauser's wasteload allocation was substantially
reduced.
Phase 3: Quaker Neck Lake Dam to Streets Ferry
A preliminary QUAL2E model was developed in early 1988 for the lower Neuse
from Quaker Neck Lake Dam to Streets Ferry using available data. The model
compared actual and permitted loads (Fig. 4). The curve representing the
prediction for actual loads (Fig. 4) closely approximates the ambient data
shown in Figure 1. If anything, the model overpredicts DO. More importantly,
the model predicts DO standard violations at permitted wasteloads indicating a
reduction from current permitted levels is necessary. Figure 4 also
demonstrates that reducing permitted loads to 5 mg/1 SODS and 2 mg/1 NH3-N
should protect the DO standard. DEM is currently performing intensive surveys
in this segment of the river to validate or modify model assumptions and to
calibrate the model.

Phase 4: Smithfield to Goldsboro
Field data being collected this summer will be used in development of a
QUAL2E model for the upper Neuse between Smithfield and Goldsboro. A complete
model of the Neuse River will than be available for basin planning.
Summary and Recommendations
Assimilative capacity in the Neuse River is limited. Ambient data,
intensive survey data, and modeling predictions indicate dissolved oxygen
standards are occasionally violated throughout the basin, particularly in the
estuarine portion. Intensive survey data and modeling predictions demonstrate
that refractory BOD loads are transported downstream and contribute to DO
problems in the lower portion of the basin. Modeling indicates that existing
permitted loads exceed those needed to protect the DO standard in several
locations throughout the lower basin. In light of the above, all new and
expanding dischargers affecting the Neuse River mainstem water quality, should
meet advanced treatment requirements including limits of 5 mg/1 SODS, 2 mg/1
NH3-N, and 6 mg/1 DO.

FIGURE 1 . Neuse River Summer D.O. Box Plots (1983-1987)
1 1 I
FALLS CLAYTON SMITHFIELD GOLDSBORO KINSTON FT BARNWE... ST FERRY BL SWIFT CK NARROWS NEW BERN
Ambient Stations

FIGURE 2. Predicted DO Conc. in Neuse River
Milburnie Dam Included
7.8
7.6
7.4
7.2
7
6.8
6.6
6.4
6.2
6
5.8
5.6
5.4
5.2
4.8
4.6
4,4
I I 1 4 1
10 20 Rwe;h
Distance in miles
30
40
50

12_
1L
10_
9_
7_
5_
DO 4-
Cmg/I)
2_,
1• _
FIGURE'-'3
NEUSE RIVER
T Cirnblent Depth Averaged Dissolved Oxygen Data
September, 1982 1987
i
Standa��-
Legend:
•Max
c CI
Streets :Swift Narrows • Wildlife New
Ferry : Creek Landing Bern
Min

0)
bO
0
C)
0
-A
10
t•
4
FIGURE 4.
Neuse River Dissolved Oxygen Prediction
Goldsboro and Kinston-Northside WLAs
103 98 93 88 83
ei
v.
58 53
Rivermiles
•
ii
418 43 38 33 .28 23 1sai18 13
Whdar
C,u.rrtMc
Ackulk
Load iKs
t1ttio Sure
itntwitect
Loodi►is

17.
LAYLAYirs Y.13 Q)piyio liA.Nor
C onsu rn9 czna7. Canal iicalC��onr�s�s
ESTABLISHED 1903
Main Office
1711 Castle Street
P.O. Box 629
Wilmington, N.C. 28402
E.I. DUPONT DE NEMOURS & COMPANY
POST OFFICE BOX 800
KINSTON, N.C. 28501-0800
ATTN: JERRY BAILEY
SAMPLE DESCRIPTION:
WASTEWATER & WELLS
TESTS/SAMPLES
CYANIDE
ARSENIC
CADMIUM
CHROMIUM
COPPER
LEAD
MERCURY
NICKEL
SELENIUM
SILVER
ZINC
TOTAL DISSOLVED SOLIDS
SULFATE
CHLORIDES
pH
UNITS
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
pfeir: Je2UE
002A
<0.02
PAGE #1 OF 2
RICHARD SPI VEY, President
919.762.7082 919.762-8956
TWX 510-937-0280
DATE RECEIVED:
DATE COLLECTED:
COLLECTED BY:
LAB I.D.#
P07 LCRO-498T
'. ( 5'01lur. 1{
003A
<0.02
7-16-90
7-16-90
J. BAILEY
EW 3090
REL.# K-015
qi,,\ G `0/66 w/ Plrt€ic
002B 003B 1F3 --
<0.002
1.011
0.006
001
0.020
0.014
<0.002
0.008
0.010
<0.001
0.095
102
3
4
5.7
ABORATORY DIRECT
#8
268
35
23
7.4

LAYs 1213 ..C.3Pinvwwsys
6onsu/ ny and n4��a/'�'#(;zn:sts PAGE #2 OF 2
ESTABLISHED 1903
Main Office
1711 Castle Street
P.O. Box 629
Wilmington, N.C. 28402
E.I. DUPONT DE NEMOURS & COMPANY
POST OFFICE BOX 800
KINSTON, N.C. 28501-0800
'ATTN: JERRY BAILEY
SAMPLE DESCRIPTION:
TESTS/SAMPLES
WASTEWATER & WELLS
TOT ORGANIC/ ON',
CO
THO— PHOSPHORUS
#7A
<5
0.107
RICHARD SPI VEY, President
919-762-7082 919 762.8956
TWX 510-937-0280
DATE RECEIVED:
DATE COLLECTED:
COLLECTED BY:
LAB I.D.#
7-16-90
7-16-90
J. BAILEY
EW 3090
PO LCRO-498T REL.# K-015
` # 8A
0.481
LABORATORY DIRECTOR
TOTAL AMOUNT: 447.00

e ozzsugizy arza7zal ziL-af l_ X;rr21.Sls
ESTABLISHED 1903
Main Office
1711 Castle Street
P.O. Box 629
Wilmington, N.C. 28402
E.I. DUPONT DE NEMOURS & COMPANY
P.O. BOX 800
KINSTON, N.C. 28501-0800
ATTN: JERRY BAILEY
SAMPLE DESCRIPTION: WASTEWATER & STREAMS
TESTS/SAMPLES
ARSENIC
MERCURY
CADMIUM
NICKEL
CHROMIUM
SELENIUM
COPPER
SILVER
LEAD
ZINC
CYANIDE
919-762-7082 919-762-8956
FAX [phone]
DATE RECEIVED:
DATE COLLECTED:
COLLECTED BY:
LAB I.D. !I
POII LCR0498T
UNITS
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
002A
<0.005
<0.002
<0.001
0.005
<0.001
003A
<0.005
<0.002
<0.001
0.007
<0.001
002B
<0.02
7-30-90
7/22-29/90
J. BAILEY
EW 3280
003B
<0.02
AA-o-<\i�
LABORATCd1 Y DIRECTOR

t
- L4W i ..s
cuisuarty areal f3irta0al ~� � d;n1rsls
ESTABLISHED 1903
Main Office
1711 Castle Street
P.O. Box 629
Wilmington, N.C. 28402
E.I. DUPONT DR NEMOURS & COMPANY
POST OFFICE BOX 800
KLNSTON, N.C. 28501-0800
'ATTN: JERRY BAILEY
SAMPLE DESCRIPTION: WASTEWATER & STREAMS
TESTS/SAMPLES
RICHARD SPI VEY, President
919.762-7082 919-762.8956
TWX 510 937-0280
DATE RECEIVED: 7-30-90
DATE COLLECTED: 7/22-29/90
COLLECTED BY: JERRY BAILEY
LA8 I.D.I/ EW•3280
PO1 LCR0498T
REL.# N/A
UNITS 002 7/22 003 7/22 UP 7/22 DOWN 7/22
TURBIDITY
TESTS/SAMPLES
NTU 0.74• 0.42 6.27 28.9
AFTER FISH
UNITS POND 7/2a, 002 7/29 003 7/29
TURBIDITY
NTU 49.9 0.89 0.74
a(19-ta_LABORATODIRECTOR

onsu rn9 crncl.`;7;ralr�ficcsl' 6Ji%r77r:51:9
EST ABI.!SHED 1903
Main Office
171 1 Castle Street
P.O. Box 629
Wilmington, N.C. 28402
E.I. DUPONT DE NEMOURS & COMPANY
POST OFFICE BOX 800
KINSTON, N.C. 28501-0800
ATTN: JERRY BAILEY
SAMPLE DESCRIPTION:
TESTS/SAMPLES
ARSENIC
CADMIUM
CHROMIUM
COPPER
LEAD
MERCURY
NICKEL
SELENIUM
SILVER
ZINC
CYANIDE
BOD
NITROGEN AMMONIA
TOTAL PHOSPHORUS
RICHARD SPI VEY, President
919-762-7082 919.762.8956
TWX 510-937.0280
DATE RECEIVED: 7-23-90
DATE COLLECTED: 7-23-90
COLLECTED BY: JERRY BAILEY
LAB I.D.f EW 3010
WATER FOR PERMIT P011 LCRO-498T REL.O K-016
UNITS
PPM
PPM
PPM
PPM
PPM
PPM <0.002 <0.002
PPM
PPM
PPM
PPM
PPM
PPM
PPM
PPM
002A
003A
�.006
0.001
<0.002
6323
6.0]4
0.014 0.012
<0.001 <0.001
0.085 0.069
002B
003B EFF. 001
<0.02 <0.02
See Attached
report
2.5
2.98
TOTAL AMOUNT: 299.00

DEPARTMENT OF ENVIRONMENT HEALTH AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
FACT SHEET
APPLICATION FOR
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT TO DISCHARGE TREATED WASTEWATER
Application No. NC0003760 Date 6/28/90
1. SYNOPSIS OF APPLICATION
Applicant's Name
E. I. Dupont de Nemours and Co.
Applicant's Address
PO Box 800
Kinston, NC 28502-0800
Facility Address
on NC Highway 11
northeast of Kinston
Type of Operation
Manufacture of polyester resin and polyester fiber
Design Capacity of Facility
3.6 MGD
Applicant's Receiving Waters
Receiving Stream: the Neuse River
Classification: C-NSW
Sub -Basin: 03-04-05

See Attachment A for a map showing the discharge location (s).
Description of Wastewater Treatment Facilities
Treatment facilities are used for wastewater discharged from outfall 001. The existing wastewater
treatment facilities consist of a 3.6 millon gallon aeration basin, secondary clarifier, post
chlorination and sludge drying. In addition, wastewater streams are monitored by three total carbon
analyzers with associated instrumentation, such that wastes containing excessively high
concentrations of organic acids and/or caustic can be diverted to one of two emergency storage
ponds for special handling.
Summary of Existing Wastewater Treatment Plant Operation
See Attachment B (for operating facilities).
Type of Wastewater (as reported by applicant)
4 % Domestic
96 % Industrial
2. PROPOSED EFFLUENT LIMITATIONS
4
•
See attached copy of Effluent Page (s) from Draft Permit.._ 04
„. - ez4
%
3 . MONITORING REQUIREMENTS . 'N.` N,
pi, iz.
,�* N.-, {
The applicant will be required to monitor regularly for flow and those parameters aiited in
Section 2 above with sufficient frequency to ensure compliance with the permit conditions.
Frequency, methods of sampling, and report dates will be specified in the final permit.
4. EHFECTIVE DATE OF PROPOSED EFFLUENT LIMITS
(AND COMPLIANCE SCHEDULE IF APPLICABLE)
5 . PROPOSED SPECIAL CONDITIONS WHICH WILL HAVE A
SIGNIFICANT IMPACT ON THE DISCHARGE
Chronic toxicity, pollutant analysis, limits from OCPSF guidelines

6. BASIS FOR PROPOSED El -FLUENT LIMITS
Limits for BOD5 and TSS were obtained by calculation using 1.931 MGD process water at
percentages falling under OCPSF guidelines Subpart C (Dacron Fiber Manufacture and 0 z�;=
Fibers) and Subpart D (Polyester Resin - Manufacture) combined with BOD5 and TSS fro
MGD of domestic waste at secondary treatment limits. The limit for pH was also obtained fr
the OCPSF guidelines. The limit for NH3 -N was obtained using the previous permit limit and a
stream modeling analysis. A phosphorus limit was added per Division policy effective May 1,
1993 as the stream is classified nutrient sensitive waters. Additional limits for organic compounds
and metals were calculated using OCPSF guidelines Subpart I with the exceptions of acenapthene,
hexachlorobenzene,4 - dichloropheno naphthalen benzo(a)anthracene, benzo(a)pyrene, 3,4 -
benzofluoranthene, benzo(k)fluoranthene, chrysene,
(phenanthren ene total chromium, total copper, total cyanide and total zinc, which are water
quality limited. The toxicity limit is based on the wastewater instream concentration under 7Q10
flow conditions. The pollutant analysis is required for all major facilities.
uoren
7 . REOUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANDARDS
8. DISCUSSION OF PREVIOUS NPDES PERMIT CONDITIONS
The previous NPDES permit contained the following limitations (expressed as monthly
averages):
Flow: 3.6 MGD
BOD, 5 Day, 20 °C: 476 lb/day
TSS: 790 lb/day
NH3 as N: 63.41b/day
Dissolved Oxygen (at chlorine contact chamber): 2.5 mg/1 minimum
pH: 6 to 9 standard units
The NPDES Permit expires on: 4/30/90
9. THE ADMINISTRATIVE RECORD
R"' ir

9. THE ADMINISTRATIVE RECORD
The administrative record, including application, draft permit, fact sheet, public noti
comments received, and additional information is available by writing the Division o
Environmental Management, Water Quality Section, P.O. Box 27687, Raleigh, North
Carolina 27611. The above documents are available for review and copying at the
Archdale Building, 9th Floor, Water Quality Section, Permits and Engineering Unit, 512
North Salisbury Street, Raleigh, North Carolina 27611 between the hours of 8:00 a.m. and
5:00 p.m. Monday through Friday. Copies will be provided at a charge of 10 cents per
page.
10. STATE CONTACT
Additional information concerning the perrmit application may be obtained at the above
address during the hours stated in item No. 9 by contacting: Rosanne Barona:at (919)
733-5083.
11. PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice - 00/00/00
Permit Scheduled to Issue - 00/00/00
%fp
PROCEDURES FOR THE FORMULATION OF FINAL DETERMINATIONS "�:
12. IONS ,%
•
0 If
a. Comment Period
The Division of Environmental Management proposed to issue an NPDES Permit to this
applicant subject to the effluent limitations and special conditions outlined above. These
determinations are tentative and are open to comment from the public.
Interested persons are invited to submit written Comments on the permit application
the Division of Environmental Management's proposed determinations to the fo
address:
. y
1 �
.(c?';\. '44' .4k
tP
DIVISION OF ENVIRONMENTAL MANAGEMENN
WATER QUALITY SECTION
POST OFFICE BOX 27687
RALEIGH, NORTH CAROLINA 27611
All comments received within thirty days folloyving the date of public notice wi 1.be
considered in the formulation of final determinations with regard to this application.
•

b. Public Hearing
The director of the Division of Environmental Management may hold a public h
there is a significant degree of public interest in a proposed permit or group o
Public notice of such a hearing will be circulated in newspapers in the geographica of
the discharge and to those on the Division of Environmental Management's mailing list at
least thirty days prior to the hearing.
c. Appeal Hearings
An applicant whose permit is denied, or is granted subject to conditions he deems
unacceptable, shall have the right to a hearing before the Commision upon making written
demand to the Director within 30 days following issuance or denial of the permit.
d. Issuance of the permit when no hearing is held
If no public hearing or appeal hearing is held, and after review of the comments received,
the Division of Environmental Management's determinations are substantially unchanged,
the permit will be issued and become effective immediately. This will be the final action of
the Division of Environmental Management.
If a hearing is not held, but there have been substantial changes, public notice of the
Division of Environmental Management's revised determinations will be made. Following
a 30-day comment period, the permit will be issued and will become effective immediately.
This will be the final action of the Division of Environmental Managemen y ; ' ess a public
or appeal hearing is granted.
co<41-4/

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Summary:
Dupont has applied to renew their NPDES permit to discharge non -process
waste water, through outfall 001, into the Nei.ise River. The permit also
is to discharge non -process water through two outfalls, 002 and 003, into
an UT to the Neuse River and Beaverdam Creek respectively.
This section of the Neuse River receives wastewater from two wastewater
treatment plants servicing the City of Kinston, Contentea MSD, and
Dupont. All these permits are due to renewal in 1994 according to the
basinwide permitting strategy. It is estimated that at that time we will
be able to allocate pollutant loads in all these facilities within the
basinwide context.
The OCPSF recommends a new list of organics to he regulated in this type
of facilities. Federal guidelines have been nppli.ed in this WLA for those
compounds in which the State has no standards, that is, effluent guidelines
have been compared to water quality concentrations, and the most stringent
were applied to the permit.
The current instream monitoring sites for a1_1. the facilities discharging in
this section of the Neuse cover the area pretty much. However, by this
WLA it is recommended that the downstream mon H r,ring site 1 r r Dupont be
relocated fi,rther downstream.
According to the permit application outfalls 002 and 003 discharge some
concentrations of metals. It is believed that these concentrations are
due to concentrated levels of background concentrations brought about
through the condensation/evaporation process carried out prior to discharge.
0

Dupont
NC0003760
030405 Neuse River
Flow calculation according to recent procedures to determine flows (below
Smithfield) in Neuse River (regulated), Dupont effluent is located at
stream mile 109.7 mi. Stoneyton Creek is located 1.4 mi. upstream.
At mouth of Stoneyton Creek the Neuse River has the following DA=
2552.3 QA= 1514 cfs S7Q10= 283.1 W7Q10 = 291.6 —'fher4 are
several large discharges in this area: The City of Kinston (Peachtree
WWTP) operates a 6.75 mgd WWTP. The City of Kinston's Northside WWTP
also discharges in the area a permitted flow of 4.5 mgd. In addition to
Dupont's discharge, a major tributary of the Neuse, Contentnea Creek,
enters the river below these three dischargers; Contentnea Creek receives
effluent from fxom the Contentnea MSD near its month and thus also
contributes to the D.O. sag in the Neuse River.
Kinston Kinston
Peachtreet Northside Dupont Contentnea Creek
4.5 mi 6.0mi 5.Omi
All these points will be due for renewal in 1.994 according to the new
basinwide permitting strategy. At that time reallocation of pollutants
will be addressed.
- I will apply effluent guidelines for BOD , TSS and pH.
- NH -N limitation will remain the same. The 63.4 #/day ***-N
limitation corresponds to 2 mg/1 at 3.6 mgd and it is due tal "spiking"
procedures.
- Pollutants for which North Carolina has no standards for streams
classifications will use Federal criteria.
- Polyiwaromatic hydrocarbons will be limited as necessary according to
the following: 09 o
CPAH = (1514 + 5.,86-cfs)(31.1'1Og/1) - 15 (0)
PAH = 8469.3 '/1
cfs

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- Toxicity- A screening bioassay performed hr. 1)Et') On 011383 showed no
toxicity
New Tox. Requirement Imo= 1.93%
Chronic Ceriodaphnia Quarterly.
- Instream data indicates "no adverse impact"
- Long-term BOD have been requested for n1.1mn_jnr discharges in the area.
Data has only been received for Dupont - CROT)/RO1) =2.0; and for Kinston
North side -+ CBOD/BOD5=2.20. To calculate ('Rnt) loading from the other
facilities and consequently determine if two downstream sites for
self -monitoring are necessary relative to t-hf, 1•)idling of all facilities
(Northside, Peachtree, Dupont and CMS) will nsrnmp the following C PD5
ratios:
MSD = 2
Peachtree WWTP = 2.00
Dupont:
Permitted: 30 mg/1 BOD5 x 2.0 = 60 CBOD mg/1
3.6 MGD x 8.34 x 60 mg/ 1 = 1801 fl / f l n v
Average last twelve mos.: 4.2 mg/1 x 2 = 8.A (MoDl mg/1.
2.5 MGD x 8.34 mg/1 = 175.14 #/dnv (ROD
Kinston - Northside
Permitted: 15 x 2 = 30 mg/1 CBOD
4.5 x 8.34 x 30 = 1125.9 #/day Minn
Average last twelve mos. = 8.8 x 2 = 17.6 mg/1 ('ROD
MSD
Permitted: 22 x 2 = 44 mg/1 CBOD
2.85 x 8.34 x 44 = 1045.8 # day/C110t)
Average last twelve mos. = aaf x 2 = 26.4 mg/ 1 r:RO)
1.72 x 8.34 x 26.4 = 378.7 # dnv/+'P0T)
Kinston -Peachtree
Permitted: 22 x 2 = 44 mg/ CBOD
6.75 x 8.34 x 44 = 2477 #/day CROP
Average last twelve mos. _
5.23 x 2 = 10.46 mg/1 CBOD
4.8 x 8.34 x 10.46 mg/1 = 418,7 t '+1 1v- (ROD
Based on the above and the current instr. enm monitoring sites for Kinston
Peachtree (KPT UP & KPT DOWN), Kinston Nort:hqd, (KNS UP & KNS DOWN) and MSD
(MSD UP & MSD DOWN) I am recommending that downstream monitoring site
for Dupont be relocated further downstream. 1,'ctream monitoring could be
reduced only to summer months. Acco d ' t () Tlnpo„t i.t is hazardous to
launch a boat during high flow ngA s

North Carolina Division of Environmental Management
Water Quality Section / Environmental Sciences Branch
Ecosystems Analysis Unit / Intensive Survey Group
5 September 1989
Memorandum
To: Tom Stockton
Thru: Jay Sauberf
From: Howard Bryant 64,16
Subject: Dupont -Kinston Longterm BOD Analysis
E.I. Dupont -Kinston NC0003760 Lenoir County
Receiving Stream: Neuse River Sub -basin: 030405
DAY BOD NH3-N TKN-N NOX-N TOTALN REPS
0
5
10
15
20
25
30
35
40
45
50
55
60
65
70
75
80
85
6.8
10.4
12.3
13.7
15.0
15.8
16.5
16.8
17.1
17.4
17.8
18.0
18.2
18.3
18.4
18.6
18.7
0.14 0.9
0.02
0.01
0.38 1.3
0.6 0.73
0.4 1.1
oa
213( -zZ
1 ° vl C, Code ; QT04
D€4G e Cock.: 31
1.3 6
5
1.5 5
4
4
4
3
3
)1:013 t;t33 003-1
3`. 2`{ 3
3
c13 3
3
o. , 3
C
62.0 3
3
3
Date Collected: 30/31 May 1989 (0930-0930)
Collected By: M Vincent
Cary Lab BOD-5: no sample Total Phosphorus: 0.67 mg/L
pH: 7.95 Sulfite test for chlorine: 2 drops/100 ml 100 % sample was seeded.
Range of BOD-5: 6.42 - 7.59 mg/L
Range of BOD-85: 17.7 - 20.2 mg/L
Test evaluation: awaiting 30 day nitrogen data

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. • • ♦
INSTREAM SELF -MONITORING DATA
MONTHLY AVERAGES
Discharger: a.J okA Permit No .: NCO 0 3-) 6 0
Receiving Stream' tio,Q.Lp Sub -basin:
Upstream Location: 100 istr.A....." Downstream Location t N,.., tw c
Upstream Downstream
DATE TEMP D.O. BOD5 COND TEMP D.O. BOD5 COND
DEC-90
NOV-90
OCT-90
SEP-90
AUG-90
JUL-90
JUN-90
MAY-90
APR-90
MAR-90
FEB-90 ! .Q, 1
JAN 90 i2_�S Q 8' • 6 q . 8 3 ,
DEC-89 i 2 to , t 10 .2
NOV-89 13.y $.ZI 13s 21
OCT-89 n S n. N . 3-
SEP-89 /3.6 6 , ( 13.47 6, _
AUG-89 71.0% s,y zy q s.3
JUL-89 ls• $ s.s 8 C. 3
JUN-89 Ls S. 15- •
MAY-89 21 `l.q 22 y g
APR-89 10 2o. 0 6. o
MAR-89
FEB-89 -1, a __ 1,c16 II. t
JAN-89 -LI 11. 1 -7.3 to •q
DEC-88 g. ti.v S•t tt• 3
NOV-88 0..`-4 a . t t'z•s 4.`f
OCT-88 _. s2 G.I is • 0\ Q. 3
SEP-88 11. A '? .1- 12.6 -7. I
AUG-88 11•1 6.Li Z 6.3
JUL-88 rn.• ,C' •1 1'1 71 6 ..1
JUN-88 ZG •y 6.1 U.. S 6 •8
MAY- 8 8 to .y 77- 120.. s -1 .1
APR-88 Is 71 8 •i IS•$ _ -q
MAR-88 tt q .1 t 1 to .1
FEB-88 q6 11.i •1 tI.o
JAN-88 S,6 tt.S"
DEC-87 q •q 10.s 9•q to .1
NOV-87 14 .1 ►n•o 14.4 q •'1
OCT-87 117- q,z In .1 q• I
SEP-87 1.ti 16,t 1•I
AUG- 8 7 1A .'1. 6 . LI 18.3
JUL-87 28.a 7• to 28,y 6.1
JUN- 8 7 2 & . -i • 6 26.8 '1, 4
MAY-87 2t._ 7.--) 22.0 L 1
APR-87 1s,o q•s i$.0 q_
MAR-87 %1.0 8.z t3.0 B.I
FEB-87 5.6 8.o 6
JAN-87 b � t2.> S-
S". 65 ('2.2

Outfalls 003 and 002
- Process water is obtained from deep wells; therefore, I will not
recommend monitoring for fluoride and TP which concentrations may be high
should process water be obtained from the city of Kinston (flouride
and phosphorus are added by WTP to city water).
- Some levels of metals found in samples for NPDES permit application
purposes may be due to concentrated levels of the background concentrations
found in the water supply. Therefore, I am recommending a quarterly metal
scan.
- Turbidity is added to permit since run off water from two areas (mostly
dirt, with some parking area and grass cover) is disposed through these
two outfalls.
- I did not request flows for these two sites. 0utfall 003 analysis does
not require flow statistics. Outfall 002 is into a dry ditch; therefore -,e
and turbidity limits should be met at effluent.