DEQ-CFW_00059788

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DUPONT COMPANY — FAYETTEVILLE WORKS
OPERATION AND MAINTENANCE PLAN
OPERATIONAL FUNCTIONS
Generation and Management of River Water Sediment
River water is pumped from the Cape Fear River to the on -site Water Treatment Plant for
suspended solids ("sediment") removal, thereby making the water usable as non -potable water
for the site's manufacturing areas. Sodium hydroxide and aluminum sulfate are added to the
water to enhance the removal of the sediment from the river water. The river water and
treatment chemicals mixture is sent to a mixing tank to ensure that the chemicals are well
distributed throughout the stream. The river water flows to a clarifier after the mixing tank.
Inside the clarifier, solids continue to precipitate out and settle on the bottom of the tank while
the clarified water flows out the top of the clarifier to the gravity filters. The impurities in the
bottom of the clarifier are sent to a collection system and then to the two (2) on -site sediment
basins. The collection system also collects the remaining sediment from the gravity filters. This
water treatment process is monitored and maintained by DuPont.
Sediment Basins - Sediment Removal
Over time the river water sediment will accumulate inside the sediment basins during the normal
operation of the river water treatment system. When the basin requires the sediment to be
removed due to excessive build up, the sediment will be removed from the basin by a backhoe
and placed into a truck to be delivered to the Borrow Area by an outside contractor. The truck
will travel north along B Avenue through the gate north of Third Street. Depending on the
consistency of the sediment, the truck will continue along B Avenue or drive through the grass
parallel to the road. If the sediment contains excessive moisture when placed into the truck,
then the truck will need to drive along the grass to mitigate the risk of creating a slick surface
along the roadway. The truck will continue along the route to the barrow pit to place the
sediment in the designated area.
Borrow Area
The area for the sediment will be prepared by Tew Grading Co. Inc. and seeded by DuPont to
allow for grass to grow prior to removing sediment from the sediment basins. Once grass has
formed and the sediment begins to be delivered to the prepared areas, DuPont will spread the
sediment along the proposed space to maintain the natural water flow. A sediment trap has
been established in the area to ensure that the sediment does not flow to the river with rainfall.
Once the last of the sediment is in the barrow pit, DuPont will seed the area with rye grass and
will manage the rye grass until it is established.
MAINTENANCE SCHEDULES
Sediment Basins
The Sediment Basin maintenance will consist of following a weekly maintenance procedures for
the equipment used to remove the sediment. Routine inspection �� will be required for any
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equipment brought by the contractor and will be performed by DuPont. The contractor is
responsible for maintaining their equipment and vehicles in good operating condition.
Borrow Area
The Borrow Area will follow the same maintenance as the Sediment Basin because most of the
equipment will be vehicles from the selected contractor. Other maintenance requirements will
be monthly visual monitoring of the sediment trap to determine if the sediment trap is in need of
repair due to excessive sediment collection from stormwater runoff. Also, if supplemental
watering is needed for the rye grass, the truck and hose(s) will be visually inspected and any
needed repairs will be made, prior to their use.
SAFETY MEASURES
The Fayetteville Works Site Engineering Site Conditions Procedure (CAP 09) contains the
general guidelines for safety and site conditions for anyone who is allowed to work on site.
DuPont has multiple standards that go into greater detail for the work that will be performed.
See attached document.
SPILL RESPONSE
Potential spills associated with the project to transfer the accumulated river water sediment from
the Sediment Basin to the Borrow Areas will be exclusively releases of oil (gasoline, diesel or
hydraulic fluid) from the mobile equipment (backhoe, dump truck, grader, etc.) that will be used
for this work. In the event of a release of oil, the source of the release will be immediately
shutdown to minimize any further releases and the site's Emergency Response Team will be
summoned. Oil absorbent pads, booms, and other materials will be applied to remove any free
oil remaining on the surface. Oil contaminated soil will be removed and containerized for
ultimate off -site disposal. The small containers of contaminated soil will be transported to the
site's permitted RCRA Container Storage Area in the Nafion® area and stored there until off -site
disposal is arranged. Roll -off containers of contaminated soil will be covered with a tarp to
prevent stormwater accumulation and will be staged at or near the area of the spill until off -site
disposal is arranged.
Any small incidental releases of the sediment (a Class A residual) from a dump truck during the
sediment's transportation from the Sediment Basin to the Borrow Area will be considered to be
a de minimus quantity and as such will be left in place.
INSPECTION PLAN
Prior to each bulk residuals land application event, either DuPont or DuPont's contractor will
inspect the residuals storage, transport, and application facilities to prevent malfunctions, facility
deterioration and operator errors resulting in discharges, which may cause the release of
wastes to the environment, a threat to human health or a public nuisance. During the period
when the sediment is being deposited in the Borrow Area, DuPont will maintain an inspection
log that includes the date and time of inspection, observations made, and any maintenance,
repairs, or corrective actions taken. DuPont will maintain this inspection log for a period of five
years from the date of inspection, and this log shall be made available to the Division upon
request.
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Additional Inspection Information
• Names and titles of personnel responsible for conducting the inspections:
Steven Davis — Shamrock Environmental — Operator in Responsible Charge
Timothy Carroll — DuPont Fayetteville Works — Contract Administrator
Mark Vano — KBR Engineering — Project Engineer
• Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are
representative of the residuals management program:
1. Biweekly inspection of the Borrow Area's residuals distribution location: The Operator
in Responsible Charge or DuPont Power Area personnel verifies the sediment is being
/ has been placed in the area designated for the placement of said material.
2. Biweekly inspection of the Borrow Area's sediment trap: The Operator in Responsible
Charge or DuPont Power Area personnel visually inspects the sediment trap for signs
of excessive sediment accumulation.
3. Weekly inspection of the condition of heavy equipment used at the Sediment Basin
and the Borrow Area during sediment removal and application: The Contract
Administrator visually inspects the backhoe(s), dump truck(s), and any other heavy
equipment for signs of oil leakage.
4. Weekly inspection of the rye grass at the Borrow Area following sediment removal and
application: The Contract Administrator visually inspects the health and condition of
the rye grass until it is established.
5. Biweekly inspection of the depth of the applied sediment in the Borrow Area during
sediment application: The Project Engineer or DuPont Power Area personnel
measures the depth of the applied sediment to ensure the Cumulative Pollutant
Loading Rates (CPLRs) are not exceeded.
Detailed description of inspection procedures including record keeping and actions to be
taken by the inspector in the event that noncompliance is observed pursuant to the
noncompliance notification requirements under the monitoring and reporting section of the
permit.
1. Biweekly inspection of the Borrow Area's residuals distribution location: The Operator
in Responsible Charge or DuPont Power Area personnel will visually verify the applied
sediment is contained wholly within the boundary of the Borrow Area. If sediment is
found to be outside the boundary of the Borrow Area, then the inspector will
immediately contact the Contract Administrator who in turn will instruct the heavy
equipment contractor to move said sediment to within the boundary of the Borrow
Area. Records of these biweekly inspections will be maintained in a logbook kept on -
site in the Power Area.
2. Biweekly inspection of the Borrow Area's sediment trap: The Operator in Responsible
Charge or DuPont Power Area personnel will visually inspect the sediment trap for
signs of excessive sediment accumulation. Should the accumulated quantity of
sediment exceed one-half of the height of the sediment trap's gravel filter/berm, then
the inspector will immediately contact the Contract Administrator who in turn will
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instruct the site's construction force to remove said sediment from the sediment trap
and return it to the sediment application area in the Borrow Area. Records of these
biweekly inspections will be maintained in a logbook kept on -site in the Power Area.
3. Weekly inspection of the condition of heavy equipment used at the Sediment Basin
and the Borrow Area during sediment removal and application: The Contract
Administrator will visually inspect the backhoe(s), dump truck(s), and any other heavy
equipment for signs of oil leakage, including fuel and hydraulic fluids. If any oil
leakage is found, the inspector will instruct the equipment operator to immediately
shutdown the equipment and immediate deploy oil abatement equipment and
materials, and finally will summon the site's Emergency Response Team to contain
and remove any released oil. Records of these weekly inspections will be maintained
in a logbook kept on -site in the Contract Administration Office.
4. Weekly inspection of the rye grass at the Borrow Area following sediment removal and
application: The Contract Administrator will visually inspect the health and condition of
the rye grass ground cover of the sediment application area until the grass is fully
established. If any issues are found during the inspection, the inspector will make the
needed contacts to remedy the problem, such as watering the grass during dry
periods, or reseeding the area if the existing grass fails to become established.
Records of these weekly inspections will be maintained in a logbook kept on -site in the
Contract Administration Office.
5. Biweekly inspection of the depth of the applied sediment in the Borrow Area during
sediment application: The Project Engineer or DuPont Power Area personnel will
measure the depth of the applied sediment to ensure the Cumulative Pollutant Loading
Rates (CPLRs) are not exceeded. Prior to the commencement of the sediment
application, the Project Engineer will calculate the target depth of the sediment so as
to ensure the Cumulative Pollutant Loading Rates (CPLRs) listed in Section II(4) of the
permit are not exceeded.
SAMPLING AND MONITORING PLAN
DuPont will report by telephone to the Fayetteville Regional Office, telephone number (910)
433-3300, as soon as possible, but in no case more than 24 hours or on the next working day
following the occurrence or first knowledge of the occurrence of any of the following:
• Any occurrence with the land application program resulting in the land application of
significant amounts of wastes that is abnormal in quantity or characteristic.
• Any failure of the land application program resulting in a release of material to surface
waters.
• Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
• Any process unit failure, due to known or unknown reasons, rendering the facility
incapable of adequate residual treatment.
• Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent
failure of a storage structure, etc.) outside normal business hours shall be reported to the
Division's Emergency Response personnel at telephone number [phone], (800) 858-
0368, or [phone]. Following the reporting such occurrences by telephone, DuPont will
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also file a written report in letter form within five days following first knowledge of the
occurrence. This report will outline the actions taken or proposed to be taken to ensure that the
problem does not recur.
Additional Sampling and Monitoring Information
Names and titles of personnel responsible for conducting the sampling and monitoring;
Steven Davis — Shamrock Environmental — Operator in Responsible Charge
Detailed description of monitoring procedures including parameters to be monitored;
1. Annual sampling of sediment for hazardous characteristics analysis: Approximately
midway through the Sediment Basin's excavation, a random sample will be taken of
the sediment and submitted for TCLP, ignitability, reactivity, and corrosivity analyses.
The needed sample containers and coolers will be obtained through Compuchem
Laboratory. The samples will be submitted to Compuchem Laboratory for analysis.
Analytical results will be reported to NC Division of Water Quality via the annual report.
2. Bimonthly sampling of sediment for metals and nutrients analysis: During the first full
week of the land application of the sediment in the Borrow Area, and every sixty (60)
days thereafter during the land application of the sediment, a random sample will be
taken of the sediment and submitted for Aluminum, Ammonia -Nitrogen, Arsenic,
Cadmium, Calcium, Copper, Lead, Magnesium, Mercury, Molybdenum, Nickel, Nitrate -
Nitrite Nitrogen, Percent Total Solids, pH, Phosphorus, Plant Available Nitrogen,
Potassium, Selenium, Sodium, Sodium Adsorption Ratio (SAR), - TKN, and Zinc
analyses. The needed sample containers and coolers will be obtained through
Compuchem Laboratory. The samples will be submitted to Compuchem Laboratory
for analysis. Analytical results will be reported to NC Division of Water Quality via the
annual report.
3. Bimonthly sampling of sediment for pathogen reduction analysis: During the first full
week of the land application of the sediment in the Borrow Area, and every sixty (60)
days thereafter during the land application of the sediment, a random sample will be
taken of the sediment and submitted for Fecal Coliform Density analysis. The needed
sample containers and coolers will be obtained through Compuchem Laboratory or a
local commercial laboratory to comply with the short hold time of the sample. The
samples will be submitted to Compuchem Laboratory or another commercial
laboratory for analysis. Analytical results will be reported to NC Division of Water
Quality via the annual report.
Sampling frequency and procedures to assure that representative samples are being
collected. Fluctuation in temperature, flow, and other operating conditions can affect the
quality of the residuals gathered during a particular sampling event. The sampling plan
shall account for any foreseen fluctuations in residuals quality and indicate the most
limiting times for residuals to meet pathogen reduction requirements (e.g. facilities that
land apply multiple times per year but have an annual sampling frequency, may need to
sample during winter months when pathogen reduction is most likely to be negatively
affected by cold temperatures).
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1. Annual sampling of sediment for hazardous characteristics analysis: Approximately
midway through the Sediment Basin's excavation, a random sample will be taken of
the sediment and submitted for TCLP, ignitability, reactivity, and corrosivity analyses.
The entire emptying of the Sediment Basin is expected to take approximately six (6)
weeks, so there should be little to no fluctuations due to weather. Given the uniform
areal sediment deposition in the basin during its twelve year active period, sediment
samples would be expected to be fairly consistent in any one area. Since the
truckloads will be comprised of an excellent vertical sediment composition, the
sample will be representative of the entirety of the sediment.
2. Bimonthly sampling of sediment for metals and nutrients analysis: During the first full
week of the land application of the sediment in the Borrow Area, and every sixty (60)
days thereafter during the land application of the sediment, a random sample will be
taken of the sediment and submitted for Aluminum, Ammonia -Nitrogen, Arsenic,
Cadmium, Calcium, Copper, Lead, Magnesium, Mercury, Molybdenum, Nickel, Nitrate -
Nitrite Nitrogen, Percent Total Solids, pH, Phosphorus, Plant Available Nitrogen,
Potassium, Selenium, Sodium, Sodium Adsorption Ratio (SAR), TKN, and Zinc
analyses. The entire emptying of the Sediment Basin is expected to take
approximately six (6) weeks, so there should be little to no fluctuations due to weather.
Given the uniform areal sediment deposition in the basin during its twelve year active
period, sediment samples would be expected to be fairly consistent in any one area.
Since the truckloads will be comprised of an excellent vertical sediment composition,
the sample will be representative of the entirety of the sediment.
3. Bimonthly sampling of sediment for pathogen reduction analysis: During the first full
week of the land application of the sediment in the Borrow Area, and every sixty (60)
days thereafter during the land application of the sediment, a random sample will be
taken of the sediment and submitted for Fecal Coliform Density analysis. The entire
emptying of the Sediment Basin is expected to take approximately six (6) weeks during
November and December, so the sampling will occur when pathogen reduction is most
likely to be negatively affected by cooler temperatures. Given the uniform areal
sediment deposition in the basin during its twelve year active period, sediment
samples would be expected to be fairly consistent in any one area. Since the
truckloads will be comprised of an excellent vertical sediment composition, the sample
will be representative of the entirety of the sediment.
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