DEQ-CFW_00060918

I
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
June l 1, 2007
Michael E. Johnson, Environmental Manager
Dupont — Fayetteville Works
22828 NC Hwy 87 West
Fayetteville, NC 28306-7332
Subject: Compliance Evaluation Inspection (CEI)
DuPont — Fayetteville Works
NPDES Permit No. NC0003573
Bladen County
Dear Mr. Johnson:
Enclosed you will find a copy of the Compliance Evaluation Inspection (CEI) report for the
inspection conducted on June 5, 2007. As part of the inspection a tour of the Wastewater
Treatment Plant was conducted. All observations are in Section D. Summary of
Findings/Comments of this inspection report. During this inspection, it was noted that the 24-
hour composite sample refrigerator temperatures were not documented for both Plant Outfall 001
and 002. North Carolina Laboratory Certification regulations address the Analytical Quality
Control Program, of which, 15A NCAC 02H .0805 (a)(7)(J) states, in part, that "Each day an
incubator ... or refrigerator is used, the temperature must be checked, recorded, and initialed...".
The documentation requirement is a quality control measure that is used to review temperature
data for the collection refrigerators in order to ensure that they are maintained at 4° C during the
entire collection time period. A range of 1.0 to 4.4 degrees Celsius is recommended as the
control range for these samples. The temperatures should be recorded when the composite
sampling event begins and also when it ends.
As a reminder, before construction shall be begun for the 85-foot clarifier that is in the
planning stage, an Authorization to Construct (A to C) is required to be issued from the Division
of Water Quality.
North Carolina
Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www ncwat:erauality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
DEQ-CFW 00060918

Mr. Johnson
Page 2
June 11, 2007
You are commended for the continued success of the wastewater treatment plant. We
appreciate the time and professional courtesy that was extended by your staff during the
inspection. If you have any questions or comments concerning this report or require
clarification on part(s) of this report, please feel free to contact me at [phone].
Sincerely,
Dale Lopez
Environmental Specialist
Enclosures: Brief Description of DuPont — Fayetteville Works WWTP
EPA Water Compliance Inspection Report
Facility Site Review (checklist)
Regional Field Inspectors Check List for Field Parameters
cc: Robert Geddie, ORC
FRO Files
Central Files
DEQ-CFW 00060919

Brief Description of DuPont — Fayetteville Works WWTP:
The Polyvinyl Fluoride (PVF) facility was under construction and is expected to go on line
before the end of the year 2007. Sentry Glass Plus (SGP), located on the North side of plant, Butacite
(West side), Nafion (East side) merged influent process and domestic flows (from the Sanitary Sewage
Lift Station at Third Street and C Street) in the Collection Sump from two lines. Flowing into the
Collection Sump was the process wastewater from PMDF (a Teflon manufacturer located on the East
side of the plant, there were 2-inch lines for the process flow and the domestic flow). The APFO
(intermediate for Teflon) wastewater was shipped out, except for the sanitary sewer. There was an odor
in the Collection Sump area, probably due to Buta-Aldehyde, and recently, a significant odor from
Nafion of Dimethyl Sulfur Oxide (DMSO). The influent had between 500 to 700 mg/L of BOD (90%
of the BOD & COD came from the Butacite Plant) and between 1000 to 2,000 mg/L of COD. Flow
could be diverted (by automatic switch -over) to a 175,000 gallon capacity Retention Tank (that handled
spills and chemical slugs), and later sent back to the Collection Sump through a two-inch line.
Normally, the flow was pumped to an 850,000 gallon capacity Equalization Basin (EQ), which had three
aerators (40 HP each) and two mixers (20 HP each). In the EQ basin, there was recirculation through a
Muffin Monster, the flow then went back to the EQ basin. The Collection Sump and the Equalization
Basin were considered as the Primary Treatment Units. The Pre -Digester Tank, Aeration Tank (20 feet
deep, with 3 feet of freeboard), and the Two Clarifier Tanks were considered as the Secondary
Treatment Units. Flow was then pumped to an aerated Pre -Digester Tank, with a 50 horsepower (HP)
aerator and a 15 HP blower. Adsorption of the hydrocarbons onto the bacteria occurred in the Pre -
Digester Tank. Flow was then pumped to an Aeration Tank (where Absorption occurred), aerated by
two blowers (each rated at 4,000 cubic feet per minute (CFM), one blower rated at 1,200 CFM, and one
BioMixer rated at 1,600 CFM). At the time of this inspection, the BioMixer was out -of -service, and it
will probably be replaced by two smaller size BioMixers. Ammonium hydroxide (28% concentration)
was used as a nitrogen nutrient source, and phosphoric acid was used for the phosphate nutrient source.
Both were continuously added to the Aeration Tank. In addition, when the production plant was down
and the biomass food source was low, sodium acetate was added to the Aeration Tank as a carbon
source to keep the biomass in good condition. Folic acid was continuously added as a micronutrient.
Flow traveled to the two circular Clarifier Tanks. #1 Clarifier Tank was 45-feet in diameter and 10-feet
deep. #2 Clarifier Tank was 55-feet in diameter and 10-feet deep. For process control, the sludge
blanket has a target range of between zero to 5 feet was maintained in each Clarifier Tank. The Return
Activated Sludge (RAS) was pumped from the two circular Clarifier Tanks to the Aeration Tank. Scum
that was collected from the Clarifier Tanks was pumped to the Equalization Basin. Effluent from the
Clarifier Tanks flowed to a 6-inch Parshall Flume. The Outfall 001 composite sampler was located at
the Parshall Flume. Outfall 001 effluent had treated wastewaters from the Sanitary Wastewater,
Demineralizer Regeneration Wastewater, Process Wastewater from the Butacite Plant Area, Process
Wastewater from Nafion Area, and process wastewater from Sentry Glass Plus. Flow from Outfall 001
traveled into a board lined ditch, which contained the boiler blow -down from Dupont oil -fired boilers,
boiler blow -down, the once -through cooling water, Nafion's low biodegradable process wastewater
from Outfall 006 (which is now out -of -service, without flow, and will be eliminated from the new
NPDES permit, that is expected to arrive in July 2007), and filter backwash that was discharged to the
Nafion ditch, which then flowed to a wood- lined ditch. Approximately 50 to 100 feet downstream of
where Outfall 001 flow commingled with flow that was in the Board Lined Ditch; the flow then passed
under a board deck that supported the Outfall 002 compositor. For compliance monitoring of samples
for chronic toxicity and according to the NPDES permit, the samples were taken downstream of the
DEQ-CFW 00060920

confluence of outfall 001 and 002. Waste Activated Sludge (WAS) flowed from the underflow of the
two Clarifier Tanks and traveled to the Dissolved Air Floatation (DAF) Tank. The solids were pumped
to a Holding Tank, then to a Feed Tank (with coagulant). The flow was thickened (with polymer
addition) in the Pre -Thickener Tank (Stream addition). Solids were dewatered in the Screw Press (with
Stream addition). The Total Solids analysis at this point ranged from 9 to 18%. A conveyor transferred
the solids to a Hold -Up Tank, where it was mixed with lime. Solids traveled along another conveyor,
then through an air and steam dryer (the air going to an Odor Scrubber and vented to the atmosphere).
The dried solids were transferred onto another conveyor, to a Sludge Waste Container, and finally to the
Roseboro Landfill (Waste Management), a commercial Subtitle D landfill. The final day filter sludge
Total Solids analysis ranged from 35 to 60%.
Nafion Manufacturing: Nafion Membrane is a plastic film used in the chloroalkali industry and in
electro chemical fuel cells. Nafion Resins are ultimately extruded into a finished film. The FLPR
Vinyl Ether and HFPO monomers are shipped to other DuPont locations to produce various
fluorochemical products such as DuPont Teflon. Wastewater .from this facility is discharged to the
WWTP.
Teflon Manufacturing: Teflon FEP resin is used in the electronics industry as a coating for wire, and
other uses. Wastewater flows to the WWTP.
Butacite Manufacturing: produces Butacite Interlayer plastic sheeting used in safety glass. Polyvinyl
butyral (PVB) resin is shipped off -site as a transfer to other DuPont locations for final processing. The
wastewater from this manufacturing facility is treated in the site's biological WWTP.
Sentry Glass Plus Manufacturing: This is an ionoplast interlayer laminate used for production of
laminated automotive safety glass and architectural safety glass. This manufacturing process started in
June 2005. No process wastewaters flow to the WWTP. Non -contact cooling. water is discharged the
wood lined ditch and ultimately to the Outfall 002.
Ammonium Perfluorooctanoate (APFO) Manufacturing: APFO is used to produce fluoropolymers and
fluorinated telomers that are shipped to other DuPont facilities. The wastewaters that are generated in
this process are collected and shipped off -site for disposal.
Proposed Polyvinyl Fluoride resins (PVF) Manufacturing: This facility will produce PVF and is
expected to begin production in October 2007. PVF is used in DuPont Tedlar fluoropolymer film
manufactured at other DuPont facilities. Tedlar is used in the photovoltaic industry (in photovoltaic
cells) and the aircraft industry for interior cabin surfaces, as well as other uses. The wastewater
generated at this site will be treated at the on -site wastewater treatment plant. Wastewater from the
PVF process will contain unreacted vinyl fluoride, with little or no BOD value. The expected
concentration of vinyl fluoride at outfall 0002 is 0.0035 Non -contact cooling water, condensate, and
storm water will be discharged to Outfall 002.
DEQ-CFW 00060921

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
.Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2 151 31 NC0003573 111 121 07/06/05 117 181 CI 19I SI 20I
Remarks
211111 11II IIIIIIII IIIIIIIIIIIIIIIIIIIIIIII IIIII{16
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 CIA --------------------------- Reserved ----------------------
67I 2.0 169 701 31 711 I 72I N I 73 W 74 751111 III 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09:30 AM 07/06/05
04/02/01
Dupont Fayetteville Works
22828 NC Highway 87 West
Exit Time/Date
Permit Expiration Date
Fayetteville NC 283067332
12:30 PM 07/06/05
06/10/31
Name(s) of Onsite Representative(s)(Titles(s)/Phone and Fax Number(s)
Other Facility Data
Robert J Geddie/ORC/910-678-1219/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Michael Johnson, 22828 NC Highway 87 West Fayetteville NC
No
283067332//910-678-1155/
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program 0 Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name( nd Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
.//
Dale Lopez `� FRO WQ//910-433-3300 Ext.712/ 67
Signature of Management Q A Review r Agency/Office/Phone and Fax Numbers Date
"7
°` e b
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1
DEQ-CFW 00060922

NPDES yr/mo/day Inspection Type
3I NC0003573 I11 12� 07/06/05 1
17 18ICI
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
During this CEI inspection, it was noted that the 24-hour composite sample refrigerator temperatures were
not documented for both Plant Outfall 001 and 002. North Carolina Laboratory Certification regulations
address the Analytical Quality Control Program, of which, 15A NCAC 02H .0805 (a)(7)(J) states, in part,
that "Each day an incubator ... or refrigerator is used, the temperature must be checked, recorded, and
initialed...".
Page # 2
DEQ-CFW 00060923

Permit: NC0003573
Inspection Date: 06/05/2007
owner - Facility: Dupont Fayetteville Works
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ Q
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ Q
Judge, and other that are applicable?
Comment:
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■
❑
Cl
0
Is the facility as described in the permit?
■
n
n
n
# Are there any special conditions for the permit?
■
0
0
0
Is access to the plant site restricted to the general public?
❑
Is the inspector granted access to all areas for inspection?
■
n
n
n
Comment: The NPDES Permit is expected to be received in July 2007.
Pump Station.- Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
n
n
n
Is the wet well free of excessive grease?
■
n
n
n
Are all pumps present?
■
n
n
n
Are all pumps operable?
■
Q
n
n
Are float controls operable?
■
❑
❑
Q
Is SCADA telemetry available and operational?
■
❑
❑
n
Is audible and visual alarm available and operational?
■
n
n
n
Comment:
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
■
n
n
n
Is the basin free of bypass lines or structures to the natural environment?
■
n
Cl
Cl
Is the basin free of excessive grease?
■
Are all pumps present?
■
n
n
n
Are all pumps operable?
■
n
n
n
Are float controls operable?
n
n
■
n
Are audible and visual alarms operable?
n
n
n
■
# Is basin size/volume adequate?
■
n
n
n
Comment:
Page # 3
DEQ-CFW 00060924

Permit: NC0003573 Owner- Facility: Dupont Fayetteville Works
Inspection Date: 06/05/2007 Inspection Type: Compliance Evaluation
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
n
n
n
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
n
n
n
Are weirs level?
■
n
n
n
Is the site free of weir blockage?
■
n
Is the site free of evidence of short-circuiting?
■
n
n
n
Is scum removal adequate?
■
n
n
Is the site free of excessive floating sludge?
■
n
n
n
Is the drive unit operational?
■
Cl
n
Is the return rate acceptable (low turbulence)?
■
n
n
n
Is the overflow clear of excessive solids/pin floc?
■
n
n
n
Is the sludge blanket level acceptable? (Approximately '/< of the sidewall depth)
■
n
n
n
Comment:
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
■
n
n
n
Are surface aerators and mixers operational?
■
n
n
n
Are the diffusers operational?
■
n
n
n
Is the foam the proper color for the treatment process?
■
n
n
n
Does the foam cover less than 25% of the basin's surface?
■
n
n
n
Is the DO level acceptable?
■
n
n
n
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
no
o
o
Comment:
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
■
n
n
Cl
Is the generator tested by interrupting primary power source?
n
n
■
n
Is the generator tested under load?
rl
❑
■
n
Was generator tested & operational during the inspection?
n
❑
■
Do the generator(s) have adequate capacity to operate the entire wastewater site?
n
n
■
n
Page # 4
DEQ-CFW 00060925

Permit: NC0003573 Owner- Facility: Dupont Fayetteville'Works
Inspection Date: 06/05/2007 Inspection Type: Compliance Evaluation
Standby Power Yes No NA NE
Is there an emergency agreement with a fuel vendor for extended run on back-up power? n ❑ ■ n
Is the generator fuel level monitored? Cl n ■
Comment: There were two power sources of electrical power: Lumberton
Weatherspoon and Duke (Progress Energy), with automatic transfer of power.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
n
n
n
Are all other parameters(excluding field parameters) performed by a certified lab?
■
n
n
n
# Is the facility using a contract lab?
■
n
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
1)
n
n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
n
n
■
n
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
n
n
■
n
Comment: The 24-hour composite sample refrigerator temperatures were not
documented for both Plant Outfall 001 and 002. After the 24-hour composites are
collected, the containers are put in an ice chest to await pick-up by the contract
laboratory.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
n
■
n
o
Is sample collected above side streams?
n
o
❑
■
Is proper volume collected?
n
n
❑
■
Is the tubing clean?
■
n
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
n
n
Cl
Is sampling performed according to the permit?
■
n
n
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
n
n
n
Is sample collected below all treatment units?
■
n
n
n
Is proper volume collected?
■
n
n
n
Is the tubing clean?
■
n
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
n
■
n
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
n
n
n
Comment: The 24-hour composite sample refrigerator temperatures were not
documented for both Plant Outfall 001 and Plant Outfall 002.
Page # 5
DEQ-CFW 00060926

Permit: NC0003573
Inspection Date: 06/05/2007
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Compliance Evaluation
Upstream / Downstream Sampling Yes
No
NA
NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? D
D
D
D
Comment:
Record Keeping Yes
No
NA
NE
Are records kept and maintained as required by the permit? ■
D
D
D
Is all required information readily available, complete and current? ■
D
D
D
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
D
D
D
Are analytical results consistent with data reported on DMRs?
■
D
D
D
Is the chain -of -custody complete?
■
D
D
D
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
D
D
D
Has the facility submitted its annual compliance report to users and DWQ?
D
D
D
■
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
D
D
■
D
Is the ORC visitation log available and current?
■
D
D
D
Is the ORC certified at grade equal to or higher than the facility classification?
■
D
D
D
Is the backup operator certified at one grade less or greater than the facility classification?
■
D
D
❑
Is a copy of the current NPDES permit available on site?
■
D
D
D
Facility has copy of previous year's Annual Report on file for review?
■
D
D
D
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
D
D
D
Is flow meter calibrated annually?
■
D
00
Is the flow meter operational?
■
D
00
(If units are separated) Does the chart recorder match the flow meter?
D
D
D
■
Comment:
Page # 6
DEQ-CFW 00060927