DEQ-CFW_00061233

DENR-FRO
SEP 2 1 2011
DuPont Fluoroproducts (��A/
22828 NC Highway 87 W v Y Y o
Fayetteville, NC 28306-7332
September 19, 2011
Dr. Sergei Chernikov
NCDENR Division of Water Quality
Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
SUBJECT: Comments on the Draft NPDES Permit
Permit NC0003573
DuPont Company — Fayetteville Works
Bladen County
Dear Dr. Chernikov:
The DuPont Company — Fayetteville Works ("DuPont") has received the subject draft NPDES
Permit, and respectively submits the following as comments to that permit:
1. Supplement to Permit Cover Sheet: In Item 1, the listing of existing wastewater treatment
facilities includes "tertiary filters"; however this site's wastewater treatment plant does not
have any tertiary filters. This bulleted item should therefore be eliminated.
2. Supplement to Permit Cover Sheet: In Item 2, the process area shown as Sentryglas® should
be SentryGlas®.
3. Supplement to Permit Cover Sheet: In Item 3, the Cape Fear River is shown as being a
Class C water, however the segment of the river receiving the DuPont effluent discharge is
now a Class WS-IV water.
4. Supplement to Permit Cover Sheet: On July 26, 2011, DuPont submitted to DWQ a letter
titled "NPDES Permit Renewal Application — Addendum 2" that included the Biocide/
Chemical Treatment Worksheet Form 101's for the five (5) chemicals that will be used with
a future cooling tower. Neither those biocide chemicals nor the cooling tower blowdown are
shown in the draft permit.
E.I. du Pont de Nemours and Company
DEQ-CFW 00061233

.. 1 :
' Dr. Sergei Chernikov
NCDENR Division of Water Quality
September 19, 2011
Page 2 of 2
5. Section A(1) — Effluent Limitations and Monitoring Requirements: The Chronic Toxicity
parameter is listed as a requirement for Outfall 001, with Note 1 specifying that the
compliance monitoring point is actually at Outfall 002. This site's DWQ inspector in the
Fayetteville Regional Office mentioned during his last inspection that he would prefer if the
permit was modified and the chromic toxicity monitoring requirement be moved to the
Outfall 002 section so that the permit matches the site's practice.
6. Section A(3) — Effluent Limitations and Monitoring Requirements: Currently the flow of
Outfall 002 is measured as the daily quantity of water pumped from the Cape Fear River into
the DuPont facility, so the "Sample Location" should be "Influent". However, a project is
underway that will reroute the final Outfall 002 effluent from entering the river downstream
of Lock and Dam No. 3 to entering the river upstream of the lock and dam. As part of this
project, a flow rate monitoring station will be installed to measure the actual daily flow of
Outfall 002, at which time the "Sample Location" would be "Effluent". It may be
appropriate to include a description of the Outfall 002 flow as being the "Influent" prior to
the completion of the project, and "Effluent" after the project.
7. Section A(3) — Effluent Limitations and Monitoring Requirements: In Note 1, the second
sentence should read: "As a participate in the Middle Cape Fear River Basin Association... ".
8. Section A(4) — Chronic Toxicity Permit Limit (Quarterly) — Outfall 001: See Comment 5
above. This site's DWQ inspector in the Fayetteville Regional Office would prefer if the
chromic toxicity monitoring requirement be specified for Outfall 002.
Should you have any questions regarding these comments, please call me at [phone].
DEQ-CFW 00061234