DEQ-CFW_00060886

4W.
DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28366-7332
November 5, 2009
Ms. Belinda Henson
NCDENR — Division of Water Quality
225 Green Street — Suite 714
Fayetteville, NC 28301
SUBJECT: Back-up ORC Visitations to Water Pollution Control System
NPDES Permit No. NC0003573
Dear Ms. Henson:
The DuPont Company — Fayetteville Works' longtime Operator in Responsible Charge ("ORC"),
Robert Geddie, has been absent from work due to a personal illness since July 10, 2009. DuPont
has several Back-up ORCs who have been working as the surrogate for the ORC during Mr.
Geddie's absence.
Pursuant to 15A NCAC 8G.0205(1)(b)(ii), the Back-up ORC may act as surrogate for the ORC
for a period not to exceed 120 consecutive days when the ORC is absent due to personal illness.
The 120 consecutive day limit would have been exceeded on November 7, 2009.
When it became known that Mr. Geddie would not return to work prior to November 7, 2009,
DuPont submitted a new Water Pollution Control System Designation Form on October 29, 2009
that designated E. Russell Rotan, who holds a Grade 3 certificate, as the site's ORC. A copy of
that form is enclosed per your request.
Pursuant to 15A NCAC 8G.0205(1)(a), the Back-up ORC may act as surrogate for the ORC for a
period not to exceed 20 percent of the system visitations required per calendar year, which for a
Biological Grade III system is five days per week, excluding holidays and weekends. Ignoring
holidays, this equates to 52 days per calendar year.
As of the October 29, 2009 submission of the Designation Form, the Back-up ORC had been
acting as the ORC surrogate for approximately 80 days in 2009.
E.I. du Pont de Nemours and Company
DEQ-CFW 00060886

Ms. Belinda Henson
NCDENR Division of Water Quality
November 5, 2009
Page 2 of 2
Mr. Rotan has ten (10) days of entitled vacation that are required to be taken in 2009, which
includes a prepaid week-long vacation trip planned near the end of 2009. Considering the
completely unexpected circumstances for the absence of the site's longtime ORC, and
recognizing that there are two Back-up ORCs available to ensure the proper operation of the
site's wastewater treatment plant, DuPont requests that the Division of Water Quality grant us
clemency with the 8G.0205 Rule limiting the time the Back-up ORC may act as the surrogate for
the ORC, and thereby allow Mr. Rotan to take his required and preplanned vacation.
If you should have any questions with this request, please feel free to call me at 678-1155.
Environmental Manager
DEQ-CFW 00060887