DEQ-CFW_00059816

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Date: 07/29/11 County: Bladen
To: Aquifer Protection Section Central Office Permittee: DuPont Company
Central Office Reviewer: A. Wessner Project Name: DuPont Co. - Fayetteville Works .
Regional Login No: ?? Application No.: W00035431
I. GENERAL INFORMATION
1. This application is (check all that apply): ® New ❑ Renewal
❑ Minor Modification ❑ Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ® 503 regulated ❑ 503 exempt
® Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 07/15/11
b. Person contacted and contact information: Mike Johnson
c. Site visit conducted by: Jim Barber
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
® Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location: 22828 NC Hwy 87 West, Fayetteville NC 28306
b. Driving Directions: From Fayetteville take Hwy 87 south toward Tar Heel. Just before the Cumberland
County/Bladen County line turn left onto County Line road. Drive approx. 0.70 miles and turn right. Drive
approx. 0.25 miles and turn left into the administration parking lot to receive victor pass and be escorted
onto plant site.
c. USGS Quadrangle Map name and number: DUART N.C. (H-23-SE)
d. Latitude: 34.844373 N Longitude:-78.833504 W (approx. center of North Basin)
e. Latitude: 34.843534 N Longitude:-78.833359 W (south side of South Basin)
f. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater): River
sediment with alum/polymer removed from raw water from the Cape Fear River, from the on -site water
treatment plant that generates process water to be used at the DuPont site.
For Disposal and Iniection Sites:
(If multiple sites either indicate which sites the information applies to copy and paste a new section into the
document for each site, or attach additional pages for each site
a. Location(s): same as above
b. Driving Directions: same as above
c. USGS Quadrangle Map name and number: DUART N.C.(H-23-SE)
d. Latitude: 34.851533 N Longitude:-78.833282 W (approx. center of 7 acre land application area)
FORM: APSARRDuPont Bladen WQ0035431July201 l.doc
DEQ-CFW 00059816

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
II NEW AND MAJOR MODIFICATIONAPPLICATIONS (this section not needed for renewals or minor
modifications, skin to next section)
Description Of Waste(S) And Facilities
1. Please attach completed rating sheet. Facility Classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
® Yes ❑ No ❑ N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ® N/A. If no, please explain: Class A permit
application doesn't require site specific field evaluations. DuPont has identified a specific site (located on
DuPont property in Cumberland County) for the water treatment plant residuals to be land applied due to
Division of Waste Management insistence that materials from DuPont not leave the property owned by DuPont
(due to PFOA) Contact LaM Stanley with the Hazardous Waste Section at 919-508-8562 for information as
needed.
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)?
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ® Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
® Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes E No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part W: See attached maps. The 100 year
floodplain associated with Willis Creek is at 68 msl The proposed land application area elevation is between
135 and 140 msl.
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or ® No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ® N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ® No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
FORM: APSARRDuPont Bladen WQ003 543 1 July201 1. doc 2
DEQ-CFW 00059817

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
III RENEWAL AND MODIFICATIONAPPLICATIONS (use previous section for new or major modification
systems)
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No.
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ® N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
FORM: APSARRDuPont Bladen WQ003543 Huly2011.doc 3
DEQ-CFW 00059818

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
FORM: APSARRDuPont Bladen WQ0035431July2Ol l.doc 4
DEQ-CFW 00059819

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
IV INJECTION WELL PERMITAPPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
❑ In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: .)
2. Does system use same well for water source and injection? ❑ Yes ❑ No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ❑ No
What is/are the pollution source(s)? . What is the distance of the injection well(s) from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? ft.
5. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ❑ Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Infection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes, explain:
3. For renewal or modification of groundwater remediation permits (of any tyne), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. If yes, explain:
4. Drilling contractor: Name:
FORM: APSARRDuPont Bladen WQ0035431July2011.doc 5
DEQ-CFW 00059820

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Address:
Certification number:
Complete and attach Well Construction Data Sheet.
FORM: APSARRDuPont Bladen WQ003543 Huly2011.doc
DEQ-CFW 00059821

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
V EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.:
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor:
Date: 00
Al-11
7-
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
.The DuPont facile generates residuals from a water treatment plant process that takes raw water from the
Cape Fear River and treats said water with alum and polymers to settle out clays/silts from the water. Process
FORM: APSARRDuPont Bladen WQ003543 Buly2011.doc
7
DEQ-CFW 00059822

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
water is used for plant manufacturing, operations Due to the history of Perfluoroctanoic Acid (PFOA or C8) use
at the site and apparent use of PFOA by upstream industry, DWM-Haz. Waste Section has identified PFOA as
a concern in groundwater at the plant site The PFOA concentration in the residuals is well below the 2L
Interim Concentration standard of 2 ppb (average concentration is .015 ppb).
Based on the very low nutrient content of the residuals the 7 acre application field will be more than adequate
to manage volume of residuals to be land applied The application rate will be around 7.50 lb of N per acre
which is well below the nutrient needs of Rye grass (proposed crop).
FORM: APSARRDuPont Bladen WQ0035431July2Ol l.doc
DEQ-CFW 00059823

,. li 91}Bfi Ile aR
e,,
tr4E8 t 91�
11t,-t gala B trE' tel �
w»�
£664 aZ`2.tiq a1ea AlaB®Lr(
raeaInq Is '
su.aP
,) o r '
•
{
1
uMa"
.ev a
y
{
n � d i
�.A
P{
Y'
71
7V
r3

�� rolajorcit.es
+ Benoimarks
— Rivers and Streams
— — Transem (Coastal?
county Boundaries
f,73 Coastal Barrier Resource Systerns
Roads
— NC Highvray
US Highway
�Interstate Highway
?oOcai Areas
F27/Ematerntonal JurMs ctlons
Coastal sounds
DuPont Fayetteville WQ0035431
F qm}ll.nmmni
®',Nyr Flooding -Fioodway(.AE) 0 3000 Feet
1G(➢y( Flooding -Has t3FE'a (AET
tirGyr Ftaoding - No 8FE's (Ap ^
TOGyr Flooding - `velocity Zone
SNyr Flooding (Shaded Xi Not tll Carolina
— — — Base Flood Elevation (Symbol) Floodplain Mapping Program
— Cross SecVons

w
q't AI
wY
. fiF('r"A �+ .n✓.. r� ': �"� 'w' `.'a"'�',, � 1ti �F�' «r ��� � :, �F �' � � :+. ti � � � � � �,
4 t
t
h. � a ,' ,� ....'' Y >F .,�w � ,F "yam +yr y" 4 ,• �' � F "� H f
. 9
k •v +k y .. ".w ..,.d Y� a 'i ` :F 4w,o '4{", 'r "� f 't v^-,,
# ,
lit
q.
*w 4y d
i.,t "ryMd -ww t
r
TC4 � " a � f I C .f n, "°'4' r'F ` ' ...,�w_,x M•� tr'a" I
J � i w• r . d .. Y �; � � .. w �.,,,�,�^.at. u�p: py ' y�.,w .rw, t,}. �'' 'yE J ^� c} 7� .yd�". :i I
4
Ar 2
�wi � ��, S" °+�»*.:•,„� � Y u�'� � III ,, �.4,c�� ��,�R ,h �
i
� 4 Ip �, ,w"r,Yxy�
A, Yar wA�^
�Cn
CD %TJ
+^.! ks 'W'mYMPW�F'� C W y�� F n i 9M ..•
CD 4 a
IV� /A� r„.v^+"*'�J a' XI
,x
°�« .� _ r a' a: t Y a»` . fl)�y style til r 7777cc">

A I
WATER POLLUTION CONTROL SYSTEM OPERATORS
CERTIFICATION COMMISSION
CLASSIFICATION
RATING SHEET FOR WATER POLLUTION CONTROL SYSTEMS
FACILITY INFORMATION:
NAME OF FACILITY:
MAILING ADDRESS: ��g Z�✓ y 7 S
COUNTY: J
CONTACT PERSON: %}% r�- JOAWSOA)TELEPHONE: ( 7/0 Z (,8 0/�S
PERMIT NO: kJQ o-D35 3 Check One: NC WQ tx HEALTH DP,
ORC: A)OT- AVA! tA13t--= A7- r#J-5 r11v- TELEPHONE: (=�
Go v7 /ZACGT ® R Ce .
RATING INFORMATION: (Before completing this section, please refer to pages 2-4)
PERMITTED FLOW: D MGD BNR? YES _
(�A� �nl�TE2 t=o2.ort ��P,� �F 4i2 i4►vF�Z
CHECK CLASSIFICATION: WASTEWATER: 1 2 3
COLLECTION: 1 2 3
SPRAY IRRIGATION SUBSURFACE LAND APPLICATION
NO
4
4
PHYSICAUCHEMICAL GRADE I N / P' GRADE II
RATED BY: ' REGION: DATE: /l
REGIONAL OFFICE TELEPHONE NUMBER: (21y) �- 3 3 3 3'1v EXT:
G
DEQ-CFW 00059827

Classification of Biological Water Pollution Control Treatment Systems:
Grade I Biological WPCS
- Septic tank/sand filter systems
- Biological lagoon systems
- Constructed wetlands and associated appurtenances
Grade II Biological WPCS
- Systems that utilize an activated sludge or fixed growth process with a permitted flow
less than or equal to 0.5 million gallons per day (mgd)
Grade III Biological WPCS
- Systems that utilize an activated sludge or fixed growth process with a permitted flow
of greater than 0.5 through 2.5 million gallons per day (mgd)
- Grade II systems that are required to achieve biological nutrient reduction *
Grade IV Biological WPCS
- Systems that utilizing an activated sludge or fixed growth process with a permitted flow
of greater than 2.5 million gallons per day (mgd)
- Grade III systems that are required to achieve biological nutrient reduction
* Biological Nutrient Reduction -
The reduction of total nitrogen or total phosphorous by an activated sludge or fixed growth
process as required by the facilities permit.
Classification of Collection Water Pollution Control Systems:
(whichever provides lowest grade)
Same grade as biological water pollution control system. Grade of system:
Based on population served:
1,500. or Less = Grade I
1,501 to 15,000 = Grade II
15,001 to 50,000 = Grade III
5Q401-,u more = Grade IV
DEQ-CFW 00059828

Classification of Spray Irrigation Water Pollution Control Systems:
Systems which utilize spray irrigation for the reuse or disposal of wasterwater.
These systems include: septic tanks, sand filter, oil/water separators, lagoons,
storage basins, screening, sedimentation. Systems other than those listed above
shall be subject to additional classification.
r------------------
Classification of Land Application of Residuals Systems:
Systems permitted and dedicated for land application of residuals that are produced by a
water pollution control system or contaminated soils.
Classification of Physical/Chemical Water Pollution Control Treatment Systems:
Grade I Physical/Chemical: Any water pollution control system that utilizes a primarily
physical process to treat wastewater. This classification includes groundwater
remediation systems. **
Grade II Physical/Chemical: Any water pollution control system that utilizes a primarily
chemical process to treat wastewater. This classification includes reverse osmosis,
electrodialysis, and ultrafiltration systems. **
** Any water pollution control system that utilizes a phyicaUchemical process to enhance an
activated sludge or fixed growth process, shall not be subject to additional classification.
Classification of Subsurface Water Pollution Control Systems:
Systems which utilize the soil for subsurface treatment and disposal of wastewater
and/or are required to have a certified operator under 15A NCAC 18A.1961. ***
***Any subsurface system that has as part of its treatment process a water pollution control
systems that may be classified under Rules .0302 through .0307 of this section shall be
subject to addional classification.
G
DEQ-CFW 00059829

Classification of Spray rrigation Water Pollution Control Systems:
Systems which utilize spray irrigation for the reuse or disposal of wasterwa::./r
These systems include: septic tanks, sand filter, oil/water separators, lag
storage basins, screening, sedimentation. Systems other than those list oo above
,shall be subject to additional classification.
ClassificationXf Land Application of Residuals Systems:
Systems pe tted and dedicated for land application
water pollution',ontrol system or contaminated soils,
Classification of
Grade I Physical/Chemical: Any
physical process to treat wastewi
remediation systems. **
Grade II Physical/Chemical: 3
chemical process to treat w tewz
electrodialysis, and ultraf tration
----------
"I -----------------------------
that are produced by a
Control Treatment Systems:
J
pollution control system that utilizes a primarily
his classification includes groundwater
water Pollution control system that utilizes a primarily
Ater. This cl cation includes reverse osmosis,
systems. **
*Any water pollution contr 1 system that utilizes a phyicaU mical process to enhance an
activated sludge or fix d growth process, shall not be subjec to additional classification.
Classification of Sub urface Water Pollution Control Systems:
Systems hich utilize the soil for subsurface treatment and dispos of wastewater
and/or a required to have a certified operator under 15A NCAC 18A: 961. ***
*** Any s bsurface system that has as part of its treatment process a water pollution ont
Sys ems that may be classified under Rules .0302 through .0307 of this section shall
bJ ct to addional classification.
DEQ-CFW 00059830

Definitions
Activated Sludge - shall mean a biological wastewater treatment process in which predominantly
biodegradable polluntants in wastewater are absorbed, or adsorbed by living aerobic organisms and
bacteria.
Chemical Process - shall mean a wastewater pollution control system process consisting
exclusively of the addition of chemicals to treat wastewater.
Collection System - shall mean a continuous connections of pipelines, conduits, pumping
stations, and other related constructions used to conduct wastewater to the water pollution
control system.
Electrodialysis System - shall mean a system utlizing a selective separation of dissolved solids
process that is based on electrical charge and diffusion through a semipermeable membrane.
Physical Process - shall mean any water pollution control system process consisting of
electrodialysis, adsorption, absorption, air stripping, gravimetric sedimentation, floation, and
filtration as a means of treatment.
Reverse Osmosis System - shall mean a system which utilizes solutions and semipermable
membranes to separate and treat wastewater.
Ultrafiltration System - shall mean a system which utilizes a membrane filter to remove
pollutants from wastewater.
Water Pollution Control System - shall mean any system for the collection, treatment, or
disposal of wastewater and is classified under the provision of G.S. 90A-37.
Note: Please refer to G.S. 90A-37 for additional information and definitions.
DEQ-CFW 00059831

Definitions
ctivated Sludge - shall mean a biological wastewater treatment process in which predominantly
bio egradable polluntants in wastewater are absorbed, or adsorbed by living aerobic organisms and
bacte
Chemical ocess - shall mean a wastewater pollution control system process consisting
exclusively of e addition of chemicals to treat wastewater.
Collection System - hall mean a continuous connections of pipelines conduits, pumping
stations, and other relatld constructions used to conduct wastewater to the water pollution
control system.
Electrodialysis System - shal ean a system utlizing a selective separation of dissolved solids
process that is based on electric harge and diffusion through a semipermeable membrane.
Physical Process - shall mean any wa r pollution control system process consisting of
electrodialysis, adsorption, absorption, aid
filtration as a means of treatment.
g, gravimetric sedimentation, floation, and
Reverse Osmosis System - shall mean a system hich utilizes solutions and semipermable
membranes to separate and treat wastewater.
Ultrafiltration System -shad mean a system which \for
ane filter to remove
pollutants from wastewater.
Water Pollution Control System - shall mean any section, treatment, or
disposal of wastewater and is classified under the proA-37.
Note: Prise refer to G.S. 90A-37 for additional information and definitions.
DEQ-CFW 00059832