DEQ-CFW_00064658

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
December 15, 1989
Mr. Tom Olcott
E. I. du Pont de Nemours & Company
P.O. Drawer Z
Fayetteville, N.C.28302
bject:
DEC 271989
ENV. MANAGEMENT
Dear Mr. Olcott: EAYETTEVILLE REG. 0 ffTO
R. Paul Wilms
Director
Permit No. NC0003573
Authorization to Construct
E. I. du Pont de Nemours & Company
Wastewater Treatment Facility
Sludge Dewatering Facilities
Bladen County
A letter of request for an Authorization to Construct was received November 14, 1989 by
the Division and final plans and specifications for the subject project have been reviewed and found
to be satisfactory. Authorization is hereby granted for the construction of sludge dewatering
facilities consisting of a DAF thickener, polymer addition, screw press and a steam heated sludge
dryer with dried sludge being disposed of in an approved landfill.
This Authorization to Construct is issued in accordance with Part III paragraph B of
NPDES Permit No. NC0003573 issued March 13, 1987 and shall be subject to revocation unless
the wastewater treatment facilities are constructed in accordance with the conditions and limitations
specified in Permit No. NC0003573.
The sludge generated from these treatment facilities must be disposed of in accordance with
G.S. 143-215.1 and in a manner approved by the North Carolina Division of Environmental
Management.
In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as may be
required by this Division, such as the construction of additional or replacement wastewater
treatment or disposal facilities.
The Fayetteville Regional Office, phone no. [phone] shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an in -place
inspection can be made. Such notification to the regional supervisor shall be made during the
normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays.
DEQ-CFW 00064658

Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been
installed in accordance with the NPDES Permit, this Authorization to Construct and the approved
plans and specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box
27687, Raleigh, NC 27611.
The Permittee shall employ a certified wastewater treatment plant operator to be in
responsible charge of the wastewater treatment facilities. The operator must hold a certificate of the
grade at least equivalent to the classification assigned to the wastewater treatment facilities by the
Certification Commission.
A copy of the approved plans and specifications shall be maintained on file by the Permittee
for the life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may
subject the Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6.
The issuance of this Authorization to Construct does not preclude the Permittee from
complying with any and all statutes, rules, regulations, or ordinances which may be imposed by
other government agencies (local, state, and federal) which have jurisdiction.
One (1) set of approved plans and specifications is being forwarded to you. If you have
any questions or need additional information, please contact Babette McKemie, telephone number
919/733-5083.
Sincerely,
R. Paul Wilms
el I *�'
cc: Bladen County Health Department
.w+aybtteville RVirional Office
DEQ-CFW 00064659

Permit No. NC0003573
Authorization to Construct
December 15, 1989
Engineer's Certification
I, , as a duly registered Professional Engineer in the State of North
Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the
project, for the
Project Name Location
Permittee hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of the approved plans and specifications.
Signature
Date
Registration
DEQ-CFW 00064660

Z-544 REV. 12-79
aUPONT
E STABt15H E01002
E. I. DU PONT DE NEMOURS & COMPANY
INCORPORATED
P. O. DRAWER Z
FAYETTEVILLE, N. C. 28302
POLYMER PRODUCTS (DEPARTMENT
February 1, 1989
M.J. Noland, Regional Supervisor illy
Department of Natural Resources
and Community Development FEB 6 1989
Wachovia Building, Suite 714
Fayetteville, NC 28301 ENV. MANAGEMENT
WETTEVILLE REG. OFFICE
Dear Mr. Noland,
This letter is in response to your letter to me of 1/11/89
concerning the status of wastewater treatment plant modifications,
sludge handling practices and lagoon closure as outlined in my previous
letter to you of 7/29/88. The status of the items you reference are
discussed below.
A. Operation of the Above -Ground Aeration Tank
The new aeration tank was placed into test service in October
and by year end was in full service after two months of successful
operation. The old aeration basin was pumped out and cleaned. The
integrity of the basin was found to be excellent after 18 years of
service. The concrete was free of corrosion and cracking, but the
expansion joints were regrouted as a precautionary measure.
Facilities to allow aeration of the sludge for its service as a
temporary holding basin have been installed.
B. Cessation of Lagooning
Pumping of fresh clarifier sludge was stopped on 1/31/89. The
sludge is being pumped to the concrete interim holding basin (old
aeration basin).
C. Closure of the Lagoons
We are currently reviewing bids from commercial vendors on the
lagoon cleanout program. We are hoping to get started well before
the 7/31/89 date mentioned in the previous letter but it is
difficult at the moment to commit to a date in the absence of a
selected vendor and completed contract. However, we are diligently
working on the negotiations at present.
BETTER THINGS FOR BETTER i-IVING
DEQ-CFW 00064661

M.J. Noland -2- February 1, 1989
Regional Supervisor
NC DNR & CD
We have contracted for disposal of the thickened sludge (passing
the paint filter test) at GSX's secure landfill in Pinewood, S.C.
and at this time do not expect the ramifications of the current
NC/SC hazardous waste controversy and embargo to close off this
disposal route. .
Once we begin this closure, we want to minimize the closure time
but the economic and technical limitations and considerations
discussed in item C.2. of the previous letter still hold. One
potential limitation is the requirement to discharge the supernate
from the lagoons to the waste treatment headwaters rather than
outfall 001 even if quality is adequate to meet 001 parameters
(decision by your office - Tommy Stevens after consultation - in
mid -January). Although we have no assurance that the quality would
be good enough to do this extensively, the operation could be
speeded considerably if it were.
One current proposal is to eliminate the sludge in as short a
time as possible if economically feasible and use a few sludge -
cleaned lagoons as interim holding basins for the supernate. After
the lagoons are emptied - as limited by the acceptable return rate
to the inlet sump - the lagoons would be closed.
D. Landfarming
We do not have a management plan worked out at this time for the
landfarming operation because of uncertainties in potential waste
sludge contaminant concentrations and problems in accurately
characterizing, and managing against, baseline groundwater quality
(due to past agricultural practices, not any manufacturing
activities on the plant). In the interim, we will
concentrate/filter fresh sludge and dispose of at the secure
landfill.
We hope to eliminate our concerns and initiate landfarming
within a year but will not chance generating a future 100 acre
groundwater problem - which could be the case at this moment without
additional characterizations, analyses and technical studies.
Obviously, from a purely economic standpoint, we wish we could
proceed at this moment because secure landfill expenses are
substantially higher than landspreading. We also have the nagging
worry that South Carolina may close our sludge disposal route
prematurely.
If you need more information, we would be glad to discuss with you
further at your convenience.
TWO:mm
Sincerely,;
Thomas W. Olcott
Environmental Coordinator
[phone] Ext. 155
DEQ-CFW 00064662

oft
Z-544 REV. 12-79 _ M E N D
'�i�ff���77���777 ®®
ESTABLISHE0002 w. JAN 10 1989
1
E. I. DU PONT DE NEMOURS St COMPANY XPARTMENT OF NATURAL RESOURCFA.
1NcoRroRATeo AND
COMMUNITY DEVELOPMENT
P. O. DRAWER Z FAYETTEVILLE REGIONAL OFFICE
FAYETTEVILLE, N. C. 28302
POLYMER PRODUCTS DEPARTMENT
January 6, 1988

« e o• STME o
•tea ; �• MAR 19 1987
State of North Carolina
FAYEiTEy1L'L,:
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor March 13, 1987
S. Thomas Rhodes, Secretary CERTIFIED MAIL
RETURN RECEIPT
Mr. T. W. Alcott
E. I. DuPont de Nemours & Company, Inc.
PO Drawer Z
Fayetteville, NC 28302
Dear Mr. Alcott:
REQUESTED
Subject: Permit
Polymer
Bladen
R. Paul Wilms
Director
No. NC0003573
Products Department
County
In accordance with your application for discharge permit received on
June 10, 1986, we are forwarding herewith the subject State - NPDES permit.
This permit is issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and
the US Environmental Protection Agency dated December 6, 1983.
If any parts, measurement frequencies or sampling requirements
contained in this permit are unacceptable to you, you may request a waiver
or modification pursuant to Regulation 15 NCAC 2B .0508(b) by written
request to the Director identifying the specific issues to be contended.
Unless such request is made within 30 days following receipt of this permit,
this permit shall be final and binding. Should your request be denied, you
will have the right to request an adjudicatory hearing.
Please take notice that this permit is not transferable. Part II, B.2.
addresses the requirements to be followed in case of change in ownership or
control of this discharge.
This permit does not affect the legal requirement to obtain other
permits which may be required by the Division of Environmental Management or
permits required by the Division of Land Resources, Coastal Area Management
Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr.
Dale Overcash, at telephone number 919/733-5083.
y%'S%aliL,.lfil;Cl�1C @,y,
AKTf- UR MIOUI !TERRY
FOR R. Paul Wilms
cc: Mr..Jim Patrick, EPA
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
DEQ-CFW 00064664

Permit No. NC0003573
STATE OF NORTH CAROLINA
DEPARTMENT OF NATURAL RESOURCES & COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
P E R M I T
To Discharge Wastewater Under The
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General
Statute 143-215.1, other lawful standards and regulations promulgated
and adopted by the North Carolina Environmental Management Commission,
and the Federal Water Pollution Control Act, as amended,
E. I. DuPont de Nemours & Company, Inc.
is hereby authorized to discharge wastewater from a facility located
at
Polymer Products Department
Fayetteville Works
Bladen County
to receiving waters designated as the Cape Fear River in the Cape Fear
River Basin
in accordance with effluent limitations, monitoring requirements, and
other conditions set forth in Parts I, II, and III hereof.
This permit shall be effective March 13, 1987
This permit and the authorization to discharge shall expire at
midnight on August 31, 1990
Signed this day of March 13, 1987
I(a!i`aAajf�i�=C;; r.
AR' T'HUR IMOUS RiiY
FOR
-----------------------------------
R. Paul Wilms, Director
Division of Environmental Management
By Authority of the Environmental
Management Commission
DEQ-CFW 00064665

Permit No. NC0003573
SUPPLEMENT TO PERMIT COVER SHEET
E. I. DuPont de Nemours & Company, Inc.
is hereby authorized to:
1. Continue the operation of the existing 1.1 MGD
wastewater treatment facility (001) consisting of
neutralization, equalization, a nutrient feed system,
an aeration basin, and two clarifiers, and
2. Continue to operate a once through cooling water system
(002) which will receive the "Nafion Area" wastewater,
and
3. Continue to operate a back wash system (003), and
4. Discharge from said facilities into the Cape Fear River
which is classified Class "C" waters in the Cape Fear
River Basin.
DEQ-CFW 00064666

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A. EFFLUENT LIMITATION AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 002 (Cooling Water
and Nafion Wastewater) Such discharges shall be limited and monitored by the permittee as
specified below:
Effluent_ Characteristics Discharge Limitations Monitoring_Recuirements
kg/day (lbs/day) Other Units (Specify) Measurement Sample *Sample
Daily Avg. Daily Max. Daily Avg. Daily Max. Frequency Type Location
Flow Continuous Recording I or E
Temperature ** ** Daily Grab E
BOD, SDay, 200C Quarterly Composite E
COD Quarterly Composite E
Fluoride **** 3476(7663) 3476(7663) Weekly Composite E
THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE COOLING WATER
*Sample locations: E - Effluent, I - Influent
**The temperature of the effluent shall be such as not to cause an increase in the temperature of the
receiving stream of more than 2.80C and in no case cause the ambient water temperature to exceed 320C.
***Daily means every day a discharge occurs except for Saturdays, Sundays and legal holidays.
E***The sample for fluoride must be taken downstream of the 001 discharge, unless or until, all neutralized
Nafion Area streams are discharged entirely into the cooling water outfall 002.
The permittee shall obtain authorization from the Division of Environmental Management prior
to utilizing any biocide in the cooling water (See Part III of this Permit).
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be
monitored daily at the effluent by grab samples
There shall be no discharge of floating solids or visible foam in other than trace amounts.

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A. EFFLUENT LIMITATION AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lastinguntil ,
the per mittee is authorized to discharge from outfall(s) serial number(s) 003 - Back gash [later'
Such discharges shall be limited and monitored by the per serial
as specified below:
Effluent Characteristics
Discharge Limitations Monitoring Requirements
kg/day (lbs/day) Other Units (S ecif
Av p Y) Measurement Sample *Sample
Daily Avg. Daily Max. Dail
Y g. Daily Maz. Frequency q Y Type Location
Flow
Total Suspended Solids Weekly Instantaneous E
30.0 mg/1 45.0 mg/1 2/Month
Settleable Solids Grab E
0.1 ml/1 0.2 ml/1 Weekly Grab Turbidity E
** **
Weekly Grab U,D
*Sample locations: E - Effluent, U - Upstream, D - Downstream
**The discharge shall not cause the turbidity of the receiving water to exceed
If the turbidity exceeds these levels due to natural background conditions, the discha
level cannot cause any increase in the turbidity in the receiving water. rge
All samples collected should be of a representative discharge.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
monitored weekly at the effluent by grab samples shall be �
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There shall be no discharge of floating solids or visible foam in other than o F trace amounts.
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A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Final
During the period beginning on the effective date of the
permit and
permittee it authorized to discharge from outfall(s) serial number(s).a oing until expiration, the
Such discharges shall be limited and monitored by the permittee as specified below:
'fluent Characteristics Discharge Limitations
v - Monitoring Requirements
K�/d (lbs/day) DailOther Units (Specify) Measu
- y Avg ""�"�..��Fi
a y ax• Oailyyg, aement Sample ** Sample
y Max.axrequency —ae:— Locat on
Flow
BOD,5Dayi20oC 117.5(259) 162.8(359) 1.1 MGD Continuous Recording I or E
TSS' '. 94.8(209) 158.8(350) 2/Month Composite E
Temperature 2/Month Composite E
Total Phosphorus Weekly Grab E
Total Nitrogen (NO2 + NO3 + TKN) Monthly Composite E
Monthly Composite E
*Sample locations: E - Effluent, I - Influent
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C+ .-.
The pH shall not be less than 6.0 standard units nory grab samgreater than 9.0 w
and shall be monitored weekly at the effluent b g standard units
ple.
There shall be no discharge of floating solids or visible foam
in other than trace amounts.

Part I
Permit No. NC
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent
limitations specified for discharges in accordance with the
folllowing schedule:
2. No later than 14 calendar days following a date identified in
the above schedule of compliance, the permittee shall submit
either a report of progress or, in the case of specific actions
being required by identified dates, a written notice of
compliance or noncompliance. In the latter case, the notice
shall include the cause of noncompliance, any remedial actions
taken, and the probability of meeting the next scheduled
requirement.
I4
DEQ-CFW 00064670

C. MONITORING AND REPORTING
1. Representative Sampling
Samples collected and measurements taken
shall be characteristic of the volume
permitted discharge. Samples collected
than daily shall be taken on a day
characteristic of the discharge over the
the sample represents.
2. Reporting
as required herein
and nature of the
at a frequency less
and time that is
entire period which
Monitoring results obtained during the previous month(s)
shall be summarized for each month and reported on a monthly
Discharge Monitoring Report (DMR) Form (DEM No. MR 1, 1.1,
2, 3,) or alternative forms approved by the Director, DEM,
postmarked no later than the 30th day following the
completed,reporting period.
The first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility,
on the last day of the month following the commencement of
discharge. Duplicate signed copies of these, and all other
reports required herein, shall be submitted to the following
address:
Division of Environmental Management
Water Quality Section
ATTN: Central Files
Post Office Box 27687
Raleigh, NC 27611
3. Definitions
a. Act or "the Act": The Federal Water Pollution Control
Act, also know as the Clean Water Act, as amended, 33 U.S.C.
1251, et. seq.
b. The "daily average" discharge means the total discharge
by weight during a calendar month divided by the number of
days in the month that the production or commercial facility
was operating. Where less than daily sampling is required by
this permit, the daily average discharge shall be determined
by the summation of all the measured daily discharges by
weight divided by the number of days sampled during the
calendar month when the measurements were made.
C. The "daily maximum" discharge means the total discharge
by weight during any calendar day.
15
DEQ-CFW 00064671

d. DEM or Division: means the Division of Environmental
Management, Department of Natural Resources and Community
Development.
e. EMC: used herein means the North Carolina Environmental
Management Commission.
f. Flow, M3/day (MGD): The flow limit expressed in this
permit is the 24 hour average flow, averaged monthly. It is
determined as the arithmetic mean of the total daily flows
recorded during the calendar month.
g. Arithmetic Mean: The arithmetic mean of any set of
values is the summation of the individual values divided by
the number of individual values.
h. Geometric Mean: The geometric mean of any set of values
is the Nth root of the product of the individual values
where N is equal to the number of individual values. The
geometric mean is equivalent to the antilog of the
arithmetic mean of the logarithms of the individual values.
For purposes of calculating the geometric mean, values of
zero (0) shall be considered to be one (1).
i. Composite Sample: These samples consist of grab samples
collected at equal intervals and combined proportional to
flow, a sample continuously collected proportionally to
flow, or equal volumes taken at varying time intervals. If a
composite sample is obtained from grab samples, the
following requirements apply. The intervals between influent
grab samples shall be no greater than hourly. Intervals
between effluent grab samples shall be no greater than
hourly except where the detention time of the wastewater in
the facility is greater than 24 hours, in which case, the
interval between grab samples shall be no greater in number
of hours than the detention time in number of days;
provided, however, in no case may the time between effluent
grab samples be greater than six hours nor the number of
grab samples less than four during any discharge period of
24 hours or less.
j. Grab Sample: Grab samples are individual samples
collected over a period of time not exceeding 15 minutes;
the grab sample can be taken manually.
W-i
DEQ-CFW 00064672

4. Test Procedures
Test procedures for the analysis of pollutants shall conform
to the EMC regulations published pursuant to N.C.G.S.
143-215.63 et seq, the Water and Air Quality Reporting Act,
and to regulations published pursuant to Section 304(g), 33
USC 1314, of the Federal Water Pollution Control Act, As
Amended, and Regulation 40 CFR 136.
5. Recording Results
For each measurement or sample taken pursuant to the
requirements of this permit, the permittee shall record the
following information:
a. The exact place, date, and time of sampling;
b. The dates the analyses were performed; and
c. The person(s) who performed the analyses.
6. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s)
designated herein more frequently than required by this
permit, using approved analytical methods as specified
above, the results of such monitoring shall be included in
the calculation and reporting of the values is required in
the DMR. Such increased frequency shall also be indicated.
The DEM may require more frequent monitoring or the
monitoring of other pollutants not required in this -permit
by written notification.
7. Records Retention
All records and information resulting from the monitoring
activities required by this Permit including all records of
analyses performed and calibration and maintenance of
instrumentation and recordings from continuous monitoring
instrumentation shall be retained for a minimum of three (3)
years. This period of retention shall be extended during the
course of any unresolved litigation or if requested by the
Division of Environmental Management or the Regional
Administrator of the Environmental Protection Agency.
I 7
DEQ-CFW 00064673

PART II GENERAL CONDITIONS
A. MANAGEMENT REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with
the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than
or at a level in excess of that authorized shall constitute
a' violation of the permit. Any anticipated facility
expansions, production increases, or process modifications
which will result in new, different, or increased discharges
of pollutants must be reported by submission of a new NPDES
application or, if such changes will not violate the
effluent limitations specified in this permit, by notice to
the DEM of such changes. Following such notice, the permit
may be modified to specify and limit any pollutants not
previously limited.
2. Noncompliance Notification
The permittee shall report by telephone to either the
central office or appropriate regional office of the
division 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:
a. Any occurrence at the water pollution control
facility which results in the discharge of significant
amounts of wastes which are abnormal in quantity or
characteristic, such as the dumping of the contents of a
sludge digester, the known passage of a slug of
hazardous substance through the facility or any other
unusual circumstances.
b. Any process unit failure, due to known or unknown
reasons, that render the facility incapable of adequate
wastewater treatment, such as mechanical or electrical
failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or
treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion
of the influent to such station or facility.
d. Any time that self -monitoring information indicates
that the facility has gone out of compliance with its
NPDES permit limitations.
I 8
DEQ-CFW 00064674

Persons reporting such
file a written report
following first knowledge
3. Facilities Operation
occurrences by telephone shall also
in letter form within 15 days
of the occurrence.
The permittee shall at all times maintain in good working
order and operate as efficiently as possible all treatment
or control facilities or systems installed or used by the
permittee to achieve compliance with the terms and
conditions of this permit.
4. Adverse Impact
The permittee shall take all reasonable steps to minimize
any adverse impact to navigable waters resulting from
noncompliance with any effluent limitations specified in
this permit, including such accelerated or additional
monitoring as necessary to determine the nature and impact
of the noncomplying discharge.
5. Bypassing
Any diversion from or bypass of facilities is prohibited,
except (i) where unavoidable to prevent loss of life or
severe property damage, or (ii) where excessive storm
drainage or runoff would damage any facilities necessary for
compliance with the effluent limitations and prohibitions of
this permit. All permittees who have such sewer bypasses or
overflows of this discharge shall submit, not later than six
months from the date of issuance of this permit, detailed
data or engineering estimates which identify:
a. The location of each sewer system bypass or overflow;
b. The frequency, duration and quantity of flow from
each sewer system bypass or overflow.
The permittee shall report by telephone to either the
central office or appropriate regional office of the
division 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 diversion from or
bypass of facilities.
FW:
DEQ-CFW 00064675

6. Removed Substances
Solids, sludges, filter backwash,
removed in the course of treatment or
shall be disposed of in accordance
in a manner such as to prevent
materials from entering waters of
waters of the United States.
7. Power Failures
or other pollutants
control of wastewaters
with NCGS 143-215.1 and
any pollutant from such
the State or navigable
The permittee is responsible for maintaining adequate
safeguards to prevent the discharge of untreated or
inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby
generators or retention of inadequately treated effluent.
8. Onshore or Offshore Construction
This permit does not authorize or approve the construction
of any onshore or offshore physical structures or facilities
or the undertaking of any work in any navigable waters.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the Director of the Division of
Environmental Management, the Regional Administrator, and/or
their authorized representatives, upon the presentations of
credentials:
a. To enter upon the permittee's premises where an
effluent source is located or in which any records are
required to be kept under the terms and conditions of
this permit; and
b. At reasonable times to have access to and copy any
records required to be kept under the terms and
conditions of this permit; to inspect any monitoring
equipment or monitoring method required in this permit;
and to sample any discharge of pollutants.
I 10
DEQ-CFW 00064676

2. Transfer of Ownership or Control
This permit is not transferable. In the event of any
change in name, control or ownership of facilities from
which the authorized discharge emanates or is contemplated,
the permittee shall notify the prospective owner or
controller by letter of the existence of this permit and of
the need to obtain a permit in the name of the prospective
owner. A copy of the letter shall be forwarded to the
Division of Environmental Management.
3. Availability of Reports
Except for data determined to be confidential under NCGS
143-215.3(a) (2) or Section 308 of the Federal Act, 33 USC
1318, all reports prepared in accordance with the terms
shall be available for public inspection at the offices of
the Division of Environmental Management. As required by
the Act, effluent data shall not be considered
confidential. Knowingly making any false statement on any
such report may result in the imposition of criminal
penalties as provided for in NCGS 143-215.1(b) (2) or in
Section 309 of the Federal Act.
4. Permit Modification
After notice and opportunity for a hearing pursuant to NCGS
143-215.1(b) (2) and NCGS 143-215.1(e) respectively, this
permit may be modified, suspended, or revoked in whole or
in part during its term for cause including, but not
limited to, the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or
failure to disclose fully all relevant facts; or
c. A change in any condition that requires either a
temporary or permanent reduction or elimination of the
authorized discharge.
I 11
DEQ-CFW 00064677

5. Toxic Pollutants
Notwithstanding Part II, B-4 above, if a toxic effluent
standard or prohibition (including any schedule of
compliance specified in such effluent standard or
prohibition) is established under Section 307(a) of the Act
for a toxic pollutant which is present in the discharge, if
such standard or prohibition is more stringent than any
limitation for such pollutant in this permit, this permit
shall be revised or modified in accordance with the toxic
effluent standard prohibition and the permittee so notified.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part
II, A-5) and "Power Failures" (Part II, A-7), nothing in
this permit shall be construed to relieve the permittee from
any responsibilities, liabilities, or penalties for
noncompliance pursuant to NCGS 143-215.3, 143-215.6 or
Section 309 of the Federal Act, 33 USC 1319. Furthermore,
the permittee is responsible for consequential damages, such
as fish killS, even though the responsibility for effective
compliance may be temporarily suspended.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee
from any responsibilities, liabilities, or penalties to
which the permittee is or may be subject to under NCGS
143-215.75 et seq. or Section 311 of the Federal Act, 33 USC
1321. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily
suspended.
8. Property Rights
The issuance of this permit does not convey any property
rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private
property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations.
I 12
DEQ-CFW 00064678

9. Severability
The provisions of this permit
provision of this permit to
invalid, the application of
circumstances, and the remainder
affected thereby.
10. Expiration of Permit
are severable, and if any
any circumstance is held
such provision to other
of this permit shall not be
Permittee is not authorized to discharge after the
expiration date. In order to receive authorization to
discharge beyond the expiration date, the permittee shall
submit such information, forms, and fees as are required by
the agency authorized to issue permits no later than 180
days prior to the expiration date. Any discharge without a
permit after the expiration will subject the permittee to
enforcement procedures as provided in NCGS 143-215.6, and 33
USC 1251 et seq.
I 13
DEQ-CFW 00064679

PART III OTHER REQUIREMENTS
A. Previous Permits
All previous State water quality permits issued to this
facility, whether for construction or operation or discharge,
are hereby revoked by issuance of this permit. The conditions,
requirements, terms, and provisions of this permit authorizing
discharge under the National Pollutant Discharge Elimination
System govern discharges from this facility.
B. Construction
No construction of wastewater treatment facilities or additions
thereto shall be begun until Final Plans and Specifications have
been submitted to the Division of Environmental Management and
written approval and Authorization to Construct has been issued.
C. Certified Operator
Pursuant to Chapter 90A of North Carolina General Statutes, the
permittee shall employ a certified wastewater treatment plant
operator in responsible charge of the wastewater treatment
facilities. Such operator must hold a certification of the grade
equivalent to or greater than the classification assigned to the
wastewater treatment facilities.
D. Groundwater Monitoring
The permittee shall, upon written notice from the Director of
the Division of Environmental Management, conduct groundwater
monitoring as may be required to determine the compliance of
this NPDES permitted facility with the current groundwater
standards.
E. Limitations Reopener
This permit shall be modified or alternatively, revoked and
reissued, to comply with any applicable effluent guideline or
water quality standard issued or approved under Sections
302 (b) (2) (c) , and (d) , 304(b)(2), and 307 (a) (2) of the Clean
Water Act, if the effluent guideline or water quality standard
so issued or approved:
1. contains different conditions or is otherwise more
stringent than any effluent limitation in the permit; or
2. controls any pollutant not limited in the permit.
I 14
DEQ-CFW 00064680

Part III Continued
Permit No. NC0003573
F. Toxicity Reopener
This permit shall be modified, or revoked and reissued to
incorporate toxicity limitations and monitoring requirements in the
event toxicity testing or other studies conducted on the effluent or
receiving stream indicate that detrimental effects may be expected
in the receiving stream as a result of this discharge.
G. The permittee shall not use any biocides except these approved in
conjunction with the permit application. The permittee shall notify
the Director in writing not later than ninety (90) days prior to
instituting use of any additional biocide used in cooling systems
which may be toxic to aquatic life other than those previously
reported to the Division of Environmental Management. Such
notification shall include completion of Biocide Worksheet Form 101
and a map locating the discharge point and receiving stream.
A. Reopener Condition
This permit shall be modified, or revoked and reissued to
incorporate new effluent limitations in the permit, if the results
of water quality studies or an instream study, reveal the new
effluent limitations are needed to protect the water quality
standards in the receiving stream.
DEQ-CFW 00064681

E. I. DU PONT DE NEMOURS & COMPANY
INCORPORATED
P. O. DRAWER Z
FAYE=EVILLE, N. C. 28302
POLYMER PRODUCTS DEPARTMENT
ENV. MANAGEMENT
FAYETTEVILLE REG. OFFICE
November 29, 1988
Permits & Engineering Unit
N.C. Dept. of Natural Resources
and Community Development
Division of Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611-7687
Dear Sirs:
In accordance with the instruction in the Authorization
to Construct issued by R. Paul Wilms on 3/28/88 (attached), I
have enclosed the engineering certification attesting that the
construction of the wastewater treatment modification at
Fayetteville Works of E.I. du Pont de Nemours & Co., Inc. in
Bladen County, Permit No. NC003573, was completed in accordance
with approved plans and specifications by the Division.
At the present time, the new aeration tank is operating
under test procedures with the former aeration basin as an
operational standby (i.e. available for aeration service in case
of problems with the new tank system.) Barring problems, this
test status will continue until the end of January, when the
basin will be converted to a sludge digester.
Sincerely;
I
Thomas W. Olcott.
Environmental Coordinator
TWO:mm
(8.13)
CC: (Cover Letter)
Bladen County Health Department
Fayetteville Regional Supervisor, M.J. Noland
Ms. Babette McKemie, Permit Branch
BETTER THINGS FOR BETTER LIVING
DEQ-CFW 00064682

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary October 26, 1988 Director
Mr. T. W. Alcott
E. I. du Pont de Nemours and Company, Inc.
P.O. Drawer 7
Fayetteville, NC 28302
Subject: OCPSF Guidelines
NPDES Permit No. NC0003573
E. I. du Pont du Nemours and Co.
Bladen County
Dear Mr. Alcott:
Reference is made to my letter to you dated July 1.4, 1.988 concerning the
reopening of the subject NPDES Permit.
After discussions with several industries that would be affected by the
reopening of the permit, a decision has been made not to reopen any permits subject to
the OCPSF Guidelines. The Division of Environmental Management: will modify your
permit to incorporate the requirements of the OCPSF guidelines during the next renewal
of your permit or during any major modification request by E. I. du Pont de Nemours
and Company.
E. I. du. Pont de Nemours and Company should thoroughly evaluate the OCPSF
guidelines. Compliance with. the OCPSF Guidelines must be achieved as expeditiously as
practicable and will be required immediately upon renewal of the permit. If the
facility cannot comply with all final effluent limitations at that- time, the Company
may request an administrative order. However, in all cases final compliance must be
achieved no later than March 31, 1992.
If you have any questions, please contact Mr.. Dale Overcash at (919) 733--5083.
cc: Mr. Dale Overcash
Fayetteville Regional Office
Mr.. Jim Patrick, EPA
smk
Si rely,
V-&Xo-_
P Wilms
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
i
i
1
An Equal Opportunity Affirmative Action Employer
DEQ-CFW 00064683

r
ST
APR
ENV MANAGEMENT
State of North Carolina FAYETTEV1LLE REa OFFICV
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary March 28, 1988 Director
Mr. Thomas Olcott
E.I. DuPont de Nemours & Company - Fayetteville
P.O. ,Drawer Z
Fayetteville, NC 28302
SUBJECT: Permit No. NCO003573
E.I. DuPont de Nemours & Company
Fayetteville Plant
Wastewater Treatment Plant Modifications
Bladen County
Dear Mr. Olcott:
A letter of request for an Authorization to Construct was received March
11, 1988, by the Division and final plans and specifications for the subject
project have been reviewed and found to be satisfactory. Authorization is
hereby granted for the construction of modifications to an existing 1.1 MGD
wastewater treatment facility consisting of a 1.5 million gallon aeration tank
with two 4,000 CFM blowers and the conversion of the existing aeration basin to
an aerobic digester.
This Authorization to Construct is issued in accordance with Part III
paragraph B of the NPIYKS Permit No. NC0003573 issued March 13, 1987, and
shall be subject to revocation unless the wastewater treatment facilities are
constructed in accordance with the conditions and limitations specified in
Permit No. NC00`03573.
The Permittee must employ a certified wastewater operator in accordance
with Part III paragraph C of the referenced permit.
The sludge generated from these treatment facilities must be disposed of
in accordance with G.S. 143-215.1 and in a manner approvable by the North
Carolina Division of Environmental Management.
In event the facilities fail to perform satisfactorily in meeting its
NPDES permit effluent limits, the permittee shall take such immediate
corrective. action as may..be-required by this:D-ivision, including the
construction of additional wastewater treatment and disposal facilities.
-- Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
DEQ-CFW 00064684

I
the State of
facilities has
specifications,
Signature
Date
NC0003573
Upon completion of construction and prior to operation of this permitted
facility, a certification must be received from a professional engineer
certifying that the permitted facility has been installed in accordance with
the approved plans and specifications. Mail the Certification to the Permits
and Engineering Unit, P.O. Box 27687, Raleigh, N.C. 27611-7687.
One (1) set of approved plans and specifications is being forwarded to
you. If you have any questions or need additional information, please contact
Ms. Babette McKemie, telephone number 919/733-5083, ext 177.
Sincerely,
e��
R. Paul Wilms
cc Bladen County Health Department
Fayetteville Regional Supervisor
Mr. Dennis R. Ramsey
John Campbell
Engineer's Certification
I as a duly registered Professional Engineer in
North Carolina, hereby certify that construction of these permitted
been completed in accordance with the approved plans and
Registration Number
DEQ-CFW 00064685

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 10, 1988
M E M O R A N D U M
TO: Arthur Mouberry, Supervisor
Permits & Engineering
r
FROM: M. J. Noland, Regional Supe isor
Fayetteville Regional Office
SUBJECT: Authorization to Construct
AC 0003573
E. I. DuPont - Fayetteville Plant
Bladen County
Our Office has reviewed this proposal and discussed this matter with
company officials. At the present time, there is no proposed change in the
permitted wastewater flow and the expansion to the Butacite operation should
not alter the wastewater characteristics. It is not believed that any permit
modification is needed at this time and our office recommends that the A/C be
issued.
Should you have further questions or need additional information, please
contact Tommy Stevens at 486-1541.
KTS/gcc
DEQ-CFW 00064686

L i�lyC,�S► r'� 1 - 1
DEQ-CFW 00064687

Z-544 REV. f2-70
Iuw�
ESTABLISHED 1902
E. I. DU PONT DE NEMOURS & COMPANY
INCORPORATED
P. O. DRAWER Z
FAYETTEVILLE, N. C. 28302
POLYMER PRODUCTS DEPARTMENT
Arthur C. Mouberry, Permit Branch Head
Division of Environmental Management
Department of Natural Resources and
Community Development
P.O. Box 27687
Raleigh, NC 27611-7687 n
Dear Mr. Mouberry:
March 2, 1988
MAR 4 .198E
PERMITS & ENGINEERING
The purpose of this letter is to submit to you plans and
specifications for a wastewater treatment plant modification in
accordance with the Part III B requirement of our NPDES Permit,
NC0003573 for Fayetteville Works of E.I. du Pont de Nemours & Co., Inc.
These modifications are required to adequately handle
expansion for the existing Butacite® manufacturing operations. In
addition, the aeration tank erected with these modifications frees up
a basin which will be converted to an aerobic sludge digester to be
used in conjunction with an independent landfarm sludge disposal
project for later permit submission.
At this time, no change in permit limits are being
requested. However, the expansion impacts are currently being
reviewed with respect to industry guidelines which could result. in a
full permit application for relief at a later time. Therefore, this
submission is strictly to gain approval for the construction of the
aeration tank and associated modifications.
The facility modifications have been designed by the Du Pont
Engineering Department in Wilmington, Delaware, who designed the
original plant and all subsequent modifications. Attached as a design
package are:
1. A summary memorandum describing the design basis and
parameters.
2. Two equipment and piping arrangement blueprints — W388407 and
W993519.
3. Two piping and instrument diagrams on the aeration tank,
sludge digester (converted aeration basin), and existing
clarifiers — W945772 and 992699.
BETTER THINGS FOR BETTER LIVING
DEQ-CFW 00064688

ARTHUR C. MOUBERRY —2— MARCH 2, 1988
Per instructions from your office, I have attached two copies of the
design package to this letter and one set to Mr. Noland's copy.
We are desirous of initiating this work as soon as possible
in order to efficiently dovetail with other construction activities
and shutdowns and thus are willing to provide whatever assistance is
necessary to expedite approval. We gladly offer to meet with your
engineering review personnel in Raleigh at your convenience if this
will speed the review process.
In case of any questions or additional need, please call me
at [phone] Ext. 155 or, in my absence, John Hollan at Ext. 274
or John Hagle at Ext. 280.
TWO:mm
2105M
CC: M.J. Noland, Regional Supervisor
Fayetteville, NC
Sincerely
Thomas W. Olcott
Environmental Control Coordinator
DEQ-CFW 00064689

ATTACHMENT A
DESCRIPTION AND DESIGN BASIS OF
EXPANDED WASTEWATER TREATMENT FACILITIES
DU PONT FAYETTEVILLE WORKS
BLADEN COUNTY, NC
Background
The Du Pont Company's Fayetteville Works manufactures Butacite*
polyvinylbutyral sheeting, Dymetrol* elastomeric tapes, TRX* -
toughener, Nafion* fluorocarbon membrane, and nylon strapping.
A major expansion in production planned in the Butacite* area
will increase the wastewater flow and organic load. The existing
wastewater treatment facilities must be expanded to handle this
increase. The treatment system expansion has been designed and
is described below, along with an explanation of the design
basis.
Existing Facilities and Capacity
The existing wastewater treatment system at the Fayetteville
Works employs activated sludge treatment and consists of the
following units:
o Emergency retention tank - 180,000 gallons
o Equalization tank - 250,000 gallons
o Aeration basin - 745,000 gallons
o Surface aerators - six 40 hp floating units in aeration basin
o Two secondary clarifiers - one 45 ft and one.55 ft diameter
Wastewater is collected in a sump in the wastewater treatment
area and is pumped into the above -ground equalization tank.
Wastewater flows by gravity from the equalization tank to the
aeration basin to the clarifiers. Combined clarifier overflow is
monitored for flow and sampled at Outfall 001. Clarifier
underflow sludge is returned to the aeration basin by pumping.
Excess sludge is currently disposed in lagoons on plant property.
However, Du Pont has agreed to eliminate this practice. A
separate project,* independent of the wastewater treatment
expansion, is underway to dewater the waste activated sludge by
belt press and spread the dewatered sludge on plant property to
grow a bermuda grass crop.
Expanded System
The expanded system will utilize the major existing facilities
listed above. However, a new aeration tank will be installed to
replace the function of the aeration basin. The aeration basin
will be converted to use as an aerobic digester. The important
features of the aeration tank and associated appurtenances are
listed below:
DEQ-CFW 00064690

-2-
o Carbon steel tank, 112 ft diameter x 20 ft liquid depth plus 4
ft freeboard. This provides a liquid volume of 1.5 million
gallons.
o Two 4000 scfm blowers to deliver diffused air in the tank.
o Air distribution laterals spaced at 5 ft 7 in intervals, with
"stations" spaced at 5 ft 7 in intervals along the bottom of
each lateral. There are a total of approximately 315
"stations" in the tank. Each "station" is a set of two 7/16"
orifices.
System Design Parameters
Studies have shown the wastewater to have the following
oxygenation characteristics:
o Alpha: 0.80
o Beta: 0.98
This means that at a minimum dissolved oxygen content of 1.5
mg/l, the ratio of field oxygen transfer to standard transfer
(ie, N/No) is between 0.65 and 0.66 for temperatures between 100C
and 30°C.
With full blower capability (8000 scfm), the air delivery for
each of the 315 stations is 25 scfm/station. Clean water studies
with diffused air through open orifices has shown that the
transfer efficiency at 20 ft water depth at 25 scfm per station
is 3.8 lbs/hr per station at standard conditions (clean water,
20°C). The maximum standard transfer in the tank is therefore:
315 x 3.8 = 1200 lbs Oz/hr or 28,700 lbs Oz/day.
The transfer efficiency under the waste conditions is:
0.65 x 28,700 = 18,700 lbs OZ/day.
Studies at Fayetteville have shown that oxygen utilization and
BOD removal is related by the factor 1.34 lbs 0Z/lb BOD5 removed.
The BOD5 capacity of the system is therefore:
18,700/1.34 = 13,900 lbs BOD5 removed/day.
At Fayetteville the peak (95th percentile) raw wasteload BOD5 is
historically 2.0 times the long-term average, expressed as
lbs/day. Thus a peak BOD5 of 13,900 lbs/day relates to a long-
term average of about 7000 lbs/day. For proper operation the
Fayetteville site must operate at an F/M ratio of no more than
about 0.2 lbs BOD5/lb MLVSS-day on a long-term average basis.
DEQ-CFW 00064691

-3-
At an average load of 7000 lbs/day BOD5 with an MLVSS
concentration of 3000 mg/1 in the 1.5 million gallon aeration
tank, the F/M would be:
7000/(3000 x 1.5 x 8.34) = 0.19 lbs BOD5/lb MLVSS-day.
With the MLVSS held at 3000 mg/l, and a ratio of VSS/TSS of 0.85
giving a total MLSS concentration of 3500 mg/l, optimum settling
characteristics are achieved. The clarifiers at the Fayetteville
Works have a combined surface area of 3964 sq ft. GLUMRB
Standards recommend a peak overflow rate of 700 gpd/sq ft (Great
Lakes -Upper Mississippi River Board of State Sanitary Engineers,
Recommended Standards for Sewage Works, 1971). This would
suggest a peak flow capacity of 2.7 million gpd at the
Fayetteville Works. However „the industrial activated sludge at
Fayetteville cannot be expected to perform as well. It is
recommended that a peak overflow rate of only 500 gpd/sq ft be
applied. This gives a peak capacity of 2.0 million gpd.
Historically, peak (95th percentile) flow has been 1.30 times the
long-term average. Therefore, the average flow capability of the
clarification system at Fayetteville is 1.5 million gpd.
Sludge production at Fayetteville is 0.225 1bs TSS/lb BOD5
removed, based on average loadings. At an average of 7000
lbs/day BOD5, 1575 lbs/day of sludge would be produced. This
sludge would be pumped to the aeration basin, which will be
converted to an aerobic digester. Periodically the sludge will
be settled and decanted to a concentration of 2% solids (20,000
mg/1) in the basin. The detention of the 745,000 gallon basin
will be:
745,000 x 0.02 x 8.34/1575 = 79 days.
This is more than adequate detention for complete aerobic
digestion and stabilitzation.
In summary, the expanded treatment system will have the following
capacities:
BOD5
Peak: 13,900 lbs/day
Average: 7,000 lbs/day
Flow:
Peak: 2.0 million gpd
Average: 1.5 million gpd
It is recognized that these capacity values are applicable for
the major equipment items, including the aeration tank, blowers,
air distribution system and clarifiers. Modifications in pumping
and piping would have to be made in order to fully accommodate
the increased flow and increased sludge recycle requirements.
DEQ-CFW 00064692

-4-
Anticipated Wasteload After Expansion
The current Butacite* expansion is expected to result in the
following raw waste load characteristics:
BOD5
Peak: 10,000 lbs/day
Average: 5,000 lbs/day
Flow:
Peak: 1.45 million gpd
Average: 1.1 million gpd
The character of the waste will be unchanged from the present
since the manufacturing procesges are intended to be essentially
similar to.current. Comparing the expected loadings to the
expanded system capacity, it is obvious that the expanded system
will be fully capable of handling the ButaciteA expansion.
DEQ-CFW 00064693

DIVISION OF ENVIRONMENTAL MANAGEMENT
November 17, 1987
Mr. Thomas W. Olcott
Environmental Control Manager
E. I. DuPont DeNemours & Company, Inc.
P. 0. Drawer Z
Fayetteville, North Carolina 28302
SUBJECT: Stream Sampling at Raw Water Intake
E. I. DuPont DeNemours & Co., Inc.
Bladen County
Dear Mr. Olcott:
This letter is in reference to a discussion that Mr. Tommy Stevens
of this office had with you on October 21, 1987 regarding the use of a
site at the company's water intake for stream sampling. Our Division
recently reissued NPDES permits to Monsanto and the City of Fayetteville
- Rockfish Creek Wastewater Treatment Plant, with both permits
requiring downstream sampling within a one mile area above Lock Number
3. Because of the limited access to the Cape Fear River in this area,
finding a suitable sampling location has been rather difficult. Any
consideration that you could give to the two facilities in using the
area at the water intake for a stream sampling location would be greatly
appreciated.
If any additional information or further details are needed, please
do not hesitate to contact Mr. Stevens at 486-1541.
Sincerely,
E.
j/rg'ionKal isor
KTS/cbm
DEQ-CFW 00064694

w
BCC: G.T. ROSENLUND*
Z-544 REV. 12-" J . E . HAGLE*
�=POINT J.M. STALLINGS - M5625
T.A. KITTLEMAN - L13W53
£STAB„SH£D1802 ( A i r only)
E. I. DU PONT DE NEMOURS & COMPANY R.A. REICH - L13W42
INCOR"RATED (Water only)
P. O. DRAWER z L.S. PARKER
FAYETTEVILLE, N. C. 28302 P.T. MC CLIMON*
@1991F
A.M. PIRESTANI
POLYMER PRODUCTS DEPARTMENT FILE: AIR - F-1-2-2.3
ID WATER - F-1-3-3
JUN 6 1986 *Cover letter only
ENV. MANAGEMENT June 3, 1986
FAYETTEVILLE REG. OFFICE
Mr. Paul G. Wilms, Director
Division of Environmental Management
N.C. Department of Natural Resources
and Community Development
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Mr. Wilms:
Enclosed are two sets of notification of emission changes
concerning a proposed expansion of the HFPO processes in the Nafione
Division of E.I. Du Pont's Fayetteville Works in Sladen County. Each set
consists of 1) a cover letter and modified AQ22 application for
sub-diminimus VOC emissions increase for the HFPO process vents and
building Waste Gas Srubber (both covered under Permit number 3339R6) and 2)
a notification of production increases which will increase the level of
current pollutants not limited in the existing outfall as required in
Management Requirements, Part II-A-1, of NPOES Permit NC 0003573.
Clarifying details are given in the cover letter and attachments with each
set.
Also enclosed is a check for 1200 to cover the permit application
and modification fee for both permits.
If any additional information or clarification is required, please
call me at the number below. We would be glad to meet with your permit
review personnel in Raleigh at their convenience if this would assist or
expedite the review processes on either permit.
Sincerely
f
Thomas W. Olcott
Environmental Control
Coordinator
(919-483-4681)
TWO:mm
1663M
CC: M.J. Noland
fayetteville.Regional Supervisor
BETTER THINGS FOR BETTER LIVING
DEQ-CFW 00064695

Z-544 REV. 12-74
E5TABliSHED i802
E. I. DU PONT DE NEMOURS & COMPANY
INCORPORATED
P. O. DRAWER Z
FAYETTEVILLE, N. C. 28302
POLYMER PRODUCTS DEPARTMENT
June 5, 1986
TO: N.C. DEPARTMENT -OF NATURAL RESOURCES
NPDES PERMITTING
SUBJECT: Notification of production increases from Nafion@ HFPO
facilities involving NPDES Permit NC 0003573 for Fayetteville
Works of E.I. Du Pont.
Background
In 1976, discussions were held with the N.C. regulatory
authorities concerning a new fluorocarbon manufacturing facility to be
added to the Fayetteville Works of E.I Du Pont located on Route 87 in
Bladen County at the Cumberland County line. The outfall from
Fayetteville Works discharges into the Cape fear River just below the
Corp of Engineers Lock No.3. Subsequently, modified NPDES Permit
NC0003573 was issued on 10/13/77 to cover this disclosure.
The principal chemical operation involved in the Nafion® Area is
the oxidation of hexafiuoropropylene (HFP) to form the
hexafluoropropylene epoxide (HFPO) which is an intermediate for
manufacture.of other fluorocarbon chemicals at this site and other
Du Pont sites. The demand on this intermediate principally at other
Du Pont sites now requires a 4.4X expansion of the facility.
Fortunately, much of the major operating equipment including the
facility Waste Gas Scrubber was significantly overdesigned for the
original capacity and major production increases can be obtained with
relatively modest changes - such as column packing,.and larger pumps
condensers and instruments - rather than major changes such as larger
vessels and building expansion.
Current Submission
Management Requirements, Part II-A-1, of the NPDES permit dictate
notification of production increases which will increase the level of
two existing pollutants, fluoride and trifluoroacetate, currently not
limited in the existing permit. A review of the last permit
application and subsequent permit indicate that neither relief from
any of the current permit discharge limitations nor changes to the
application information regarding the flows from the Nafion®
Manufacturing operation are needed.
BETTER THINGS FOR BETTER LIVING
DEQ-CFW 00064696 .

N.C. DEPARTMENT OF NATURAL RESOURCES
PAGE 2
The increases in the two non -limited pollutants to the outfall are
shown in attachment 1. Toxicity testing shows that concentrations are
not acutely toxic to representative aquatic life even at the
concentration of our undiluted outfall. These toxicological data are
presented in Attachment 2 (previously submitted to Mr. Wilms on 3/7/85
in conjunction with the 1985 permit renewal). The maximum
concentration tested were 1.6 times the outfall fluoride concentration
and 2.5 times the outfall trifluoroacetate concentration. After
mixing with the 7Q10 minimum, the maximum fluoride would only be 10%
of the drinking water standard.
As an additional "housekeeping" item concerning the permit, the
"Supplement to Permit Cover Sheet" page, Item 1, should indicate a
111_1 mgd wastewater treatment facility ... and two clarifiers" not "a
0.5 mgd" and'"a clarifier".
Sincerely
Thomas W. Olcott
Environmental Control
Coordinator
(919) 483-46Bl
TWO:mm
l 665M
DEQ-CFW 00064697

ATTACHEMENT I
COMPARATIVE LEVELS - NON -LIMITED POLLUTANTS
lbs/day
Outfall Conc., ppm*
Max. River Conc.
@ 7Q10, ppm**
CURRENT'PRODUCTION
FLUORIDE TRIFLUOROACETATE
700 350
12 6
< 0.2 10.1
THIS APPLICATION
FLUORIDE TRIFLUOROACETATE
1900 1500
33 26
0.4 0.3
* At 7 million gpd outfall flow
** 859 ft3/sec for Cape Fear River at 8laden-Cum6erland County line
per information from Fayetteville Regional Office
TWO:mm
1665M
DEQ-CFW 00064698

ATTACHMENT 2
FOR DU PONT USE ONLY
E. I. du Pont de Nemours and Co., Inc.
Haskell Laboratory for Toxicology and Industrial Medicine
Elkton Road, P. 0. Box 50,
Newark, Delaware 19714
•HASKELL LABORATORY REPORT NO. 522-84 MR NO. 7377-001
4
Material Tested* Haskell No.
Water, Waste, Fayetteville A-104
Unchlorinated mix \\
(/'Jo CoOLfN(r Wf?-6(� v/LUTIbNJ
52 ppm Fluoride, 65 ppm Trifluoroacetate
Study Initiated/Completed
il/12JF34-11J1bJF34 -
96-HOUR LC50** TO BLUEGILL, .91INF SH
SuTmary: Unchiorinated mix wastewater was not acutely toxic to bluegill
sunfish under static, unaerated test conditions during a 96-hour exposure
period, ,.
Objective: To determine thG acute toxicity of the test material to a warm
freshwater fish.
Procedure: The test material, in original form, was introduced into
ca=ercial, glass, rectangular 5 1/2-gallon aquaria and diluted with
laboratory well water to yield the desired exposure concentrations in 15
liter final volunes. An identical vessel containing only laboratory well
water was desig nat-od as the control. •'
Stability of the test material in water was not determined because it is
not a critical factor in static acute aquatic tests.
DEQ-CFW 00064699

Ten juvenile, unsexed bluegill sunfish (Le is macrochirus) fran Sea
Plantation Inc., Salem, Massachusetts with a 4.1 cm mean standard length
(range 3.3 to 4.5 cm) and 1.25 g mean wet weight (range 0.57 to 1.64 g) were
randomly assigned to each test vessel. The fish were in our laboratory for
12 days before being used For this test. Bluegil.l sunfish are identified by
labeling the culture and test vessels. Fish were not fed for 48 hours prior
to or during the exposure. The test- solutions were not- aerated and
temperature was maintained at 22°C. Photoperiod was maintained at 16 hours
light: 8 hours dark. Mortality counts and observatipns were made every 24
hours during the 96-hour exposure period.
Dissolved''`oxygen Was measured in the control, low, meditun, and high test
concentrations at the beginning of the test and at 24-hour intervals during
the 96-hour exposure period. The pH was measured in the control, low,
medium, and high test concentrations at the beginning of the' test and at
24-hour intervals during the 96-hour exposure period. Total alkalinity,
hardness (EDTA), and conductivity were measured at the beginning of the test
in the control, low, mediun, and high test concentrations.
All records from this test will be maintained at Haskell Laboratory .for
'.bx3co1ogy and .Industrial Medicine or at the Du Pont Hall -of Records.
Results: Tsst results for bluegill sunfish are pressntsd in Tabls I.
ilnchivrinated mix wastewater was not acutely toxic to bluegill sunfish under
static, unaerated test conditions during a 96-hour exposure period.
The chemical and- physical parameters measured -during the tit, reported
in 'Table II, were all within acceptable ranges.
Unchlorinated mix wastewater
** LC5O = The concentration which is lethal to 50% of a test
during the specified time period, population
- 2 -
DEQ-CFW 00064700

Report bys/L111�C-
Charles L. Hall
t
Technician
Approved by
Study Director:C�1�f
David G. Hutton
Consultant, Envirorunental Sciences
Approved by'. {"c jC. • :Lc. _ . '%
Carol D. LU754hfield
.Sect -inn qj1pprvisnr,(lronmental Biology
r.LH:IDGH: CDL:JCW,- 3 td : AQ- 3 � 7 )
Date Issued: November 29, 1984
Haskell Lab Report No. 522-84
There are 5 pages in this report.
DEQ-CFW 00064701

TABLE I
RESULT'S OF A 96-HOUR ACUTE: TOXICITY TEST
WITH BLUEGILL SUNFISH EXPOSED TO A-104. (MR 7377-001)
Nominal Test
Concentration, Observed Mortality (�)
(%) 24 Hr. 48 Hr. 72 Hr. 96 Hr.
100 0 0 0 0
75 0 0 0 0
56 0 0 0 0
42 0 0 0 0
32 0 0 0 0
24 0 0 0 0
18 0 0 0 0
13 0 0 0 0
10 -D . 4 0
1 0 0 D 0
0.1 a 0 0 0
H2O Control
DEQ-CFW 00064702

TABLE II
RESULTS OF PHYSICAL, AND CHEMICAL PARAMETERS
MEASURED DURING A 96-HOUR ACUTE TOXICITY TEST
WITH BLUEGILL SUNFISH EXPOSED TO A-104. (MR 7377-001)
Nominal Test
100%
42%
0.1%
Control
Concentrations (%)
(High)
(Mediun)
(r:ow)
H00
Dissolved Oxygen (mg/L)
0 Hr.
8.2
8.2
8.5
8.8
24 Hr.
7.8
7.7
7.8
7.5
48 Hr.
7.2
7.0
7.0
6.3
72 Hr.
7.0
6.9
6.8
5.8
96 Hr.
6.4
6.4
6.3
5.0
p
D .Fir.
7.5
7.4
7.3
7.2
24 Hr.
7.5
7.4
7, 3
7,2
48 Hr.
7.5
7.4
7.3
7.2
72 Hr.
7.5
7.4
7.3
7.2
45 Hr.
7.5
7.4
7.2
7.1
7btal Alkalinity (mg/L
as CaCO3-)
0 Fir.
.220
96
78
B 1
EDTA Hardness (mg/L
as CaCO')
0 Hr.
69
76
73
74
Conductivity (umhos/cm)
0 Hr.
420
273
170
165
- 5 -
DEQ-CFW 00064703

M
FOR DU PONT USE ONLY
E. I. du Pont de Nemours and Co., Inc.
Haskell Laboratory.for Toxicology and Industrial Medicine
Elkton Road, P. 0. Box 50,,
Newark, Delaware 19714
HASKELL LABORATORY REPORT NO. 523-84 MR NO. 7377-001
Material Tested Haskell No.
Water, Waste, Fayetteville A-104
Unchlorinated mix
(Nb Coo' "J(r W iTFA- TD I,Lrj'iDN)
52 P tn Fluoride, 65 m Trifluoroacetate
Ludy Ini iatBid/Completed
11/13/84-11115/84
40-4iDllR EMU" TO DAPHNIA MAMA
Sim- rnarY: Unchlorinated mix wastewater exhibited very low acute toxicity to
Daphnia magna.under static unaerated test conditions during a 48-hour
exposure period. There was 20% mortality in the 100% waste concentration and
ON mortality in the 75% concentration.
Objective: To determine the acute toxicity of the Last material to a
macroinvertebrate Daplinia magna.
Procedure: 'The test material, as received was diluted with laboratory mass
-culture well water to yield the desired exposure concentrations. After
mixing, 200 mL aliquots of each concentration were introduced into each of
two separate 25U mL glass exposure vessels. Two identical vessels containing
only laboratory mass culture water were designated as controls. Stability of
the test material in water was not determined because it is not a critical
factor in static acute aquatic tests.
DEQ-CFW 00064704

Ton Haskell bred daphnids (_Daphnia magna) less than 24 hours old were
randomly assigned to each vessel. Haskell bred daphnids Daphnia magna are
identified by labeling the culture and test vessels. Food was not provided
during the test. Test- solutions were not aerated and temperature was
maintained between 19.6 and 20.0°C. Photoperiod was maintained at 16 hours
light:8 hours dark.
Immobility eounla and observations were made at 24 and 411 hours after the
exposure was initiated. Dissolved oxygen and pH were measured in the
controls, low, medium, and high exposure solutions at the beginning, and
after 24 hours, and 48 hours of exposure. The total* alkalinity, hardness
(EDTA), and conductivity of the controls, low, medium, and' high exposure
solutions were m.easured•at the beginning of the exposure.
All raw data and final reports are stored at Haskell Laboratory for
Toxicology and Industrial Medicine, Newark, DE or in the Du Pont Hall of
Records, Wilmington, DE.
Results: Percent immobilities for Daphnia ma na expDsed " unchlorinaL-ed mix
wastewater are prBsentad in Table 1. The 4B-hour EC5D -vas not calculated
bacauss the result W0uW atmw )1110 0.
The chemical and physical parameters measured during the test aze.r�pDr�Bd in
-Tzb1B -U. All ware miYhin acceptable ranges far this study.
* Synonyms: UnchlDrinaksd -nix wa_-"watar
x EC50 = The concentration which causes immobility to 50% of a test
population during the specified time pBrind.
- 2 -
DEQ-CFW 00064705

Report by:
James W. Wetz 1
Technician.
Approved by �.
Study Director:-L:� L� •� ���.c.��o,�
David G. Hutton
Consultant, Environmental Sciences
Approved
PP b : Y
Larnl D. la E i a lrl
SEotion Supervisor, - iT=ental Biology
JWW:DGH:CDL:JCW:jtd:AQRP-3(8)
Date Issued: November 29, 1984
Haskell Lab. Report No. 523-84
THERE ARE 5 PAGES IN THIS REPORT.
-3-
DEQ-CFW 00064706

TABLE 1
RESULTS OF A 48-HOUR ACUTE TOXICITY TEST
WITH DAPHNIA MAGNA EXPOSED TO A-104. (MR 7377-001)
Nominal Test
Concentrations
100'
75
56
42
32
24
18
13
10
1
fl.1
11 0 ContTD i
Observed
Immobility
(9S)
24
Hours
48
Hours
A*
s*
A*
p*
0
0
40
0
0
'0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
fl
0
i3
0
D
0
D
0
A
0
0
0
D
0
Si
D
Rap-li ata �cPQ-84Js-e bens -cat-alm-ng t-en -daphnids
DEQ-CFW 00064707

TABLE II
RESULTS OF PHYSICAL AND CHEMICAL
PARAMETERS
MEASURED DURING
A 48-HOUR ACUTE TOXICITY I•ESI*
WITH DAPHNIA MAGNA
EXPOSED TO A-104.
(MR 7377-001)
Nominal Test
100
24
0.1
Control
Concentrations
(pb) (High)
(Medium)
(Low)
H90
Dissolved Oxygen
(mg/L)
0 Hr.
8.1
8.4
8.4
8.6
24 Hr.
7.5
8.2
8.4
8.4
48 Hr.
6.8
7.9
8.2
8.2
PH
11 Hr.
7.7
B.4
.B-5
B.S
24 Hr.
B4O
B.3
B_4
B_4
48 Hr.
8.2
8.3
8.2
8.2
Total Alkalinity (mg/L as CaCO
0 Hr. 435 181 107 110
EDTA Hardness (mq/L as CaCO
0 Hr. 28 75 90 90
Conductivity (pmhos/cm)
0 Hr. 2200 800 195 190
- 5
DEQ-CFW 00064708

'3..�..mot'
H% �/ 4 k l i ti6{{ yam!
.\��'•4'' �'F.k-e
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 30, 1986
M E M O R A N D U M
TO: Arthur Mouberry, Head
Permitting and Engineering Branch
FROM: M. J. Noland, Regional Supervis®RIGINAL SIGt4�D 5Y
Fayetteville Regional Office FAP!`-)t11 J. T•swy/"+r`�
SUBJECT: Authorization to Construct
NPDES Permit No. NCO003573
B. I. DuPont - Fayetteville Works
Bladen County
We have completed our review of the proposal by E. 1. DuPont to con-
struct an additional clarifier and increase the aeration capacity of the
biopond. These changes will not result in an increase of wastewater flow
from this facility, but will enable the facility to more adequately handle
their existing process wastewater flow. On several occasions the plant has
had problems with loss of solids from the existing plant, and these additions
should eliminate this problem.
It is our recommendation that an Authorization to Construct be issued
for these additional facilities.
KTS/lcr
DEQ-CFW 00064709

Z-544 REV. 12-7a
Qu— I P �.���
ESTA11I114ED1802
E. I. DU PONT DE NEMOURS & COMPANY
INCORPORATED
P. O. DRAWER Z
FAYETTEVILLE, N. C. 28302
POLYMER PRODUCTS DEPARTMENT
Arthur C. Mouberry, Permit Branch Head
Division of Environmental Management
Department of Natural Resources
and Community Development
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Mr. Mouberry:
BCC: COVER LETTER AND
DESIGN MEMO ONLY
J.R. BROADWAY
J.E. HAGLE
R.J. MC DONALD
R.A. REICH - L13W42
G.T. ROSENLUND
J.M. STALLINGS - M5625
March 18, 1986
® -' ` 777
rt.?I .i3 � 1
�.✓ l �/Its kkk���
MAR 19 19861
ENV. Mk`/. 4.,, _A`T
FAYETTEVILLE 6, r�ICE
This letter and design package is a request for authorization
to construct an additional clarifier and expand.biopond aeration
capability to the existing activated sludge waste treatment facilities
at Du Pont, Fayetteville Works, NPDES Permit NC0003573. The plant is
located on the northern border of Bladen County on the west bank
plateau of the Cape Fear River.
These additional clarification facilities are needed:
1. to minimize the chances for costly shutdowns of manufacturing
operations which result from clarifier mechanical or operating
problems with our single clarifier at current loads.
2. to provide additional settling time during the periodic sieges of
poor floc settling and also thereby minimize the use of polymers
for solids control.
3. to make Fayetteville Works a more economically competitive site
within the company for manufacturing expansions.
Rather than limit design to the minimum duplication, the
design philosophy used was to provide sufficient capacity to
accomodate any foreseeable expansions in BOD and hydraulic loads.
Therefore, although the same basic standard equipment design was used,
a 10-foot larger diameter Envirex (Rexnord) clarifier and 100 hp of
additional floating aerator capacity were incorporated in addition to
enlarged piping and additional pumping capacity. This provides
significant additional hydraulic and oxidative capacity as defined in
the design summary. (Several plant expansions are currently being
studied but have not developed to the point of applying for permits at
this time.)
BETTER THINGS FOR BETTER LIVING
DEQ-CFW 00064710

ARTHUS C. MOUBERRY -2- MARCH 17, 1986
The additions were designed by the Du Pont Engineering
Department in Wilmington, Delaware, who designed the original plant.
Attached are:
1. A summary memorandum on the design basis.
2. Two arrangement blueprints on the modified plant - W391725S and
W391726.
3. Two piping and instrument blueprints on the modified plant -
W384963 and W588832.
As I mentioned on the telephone last week, we are willing to
provide any assistance necessary to expedite this approval in order to
make the tie-ins in conjunction with a planned manufacturing plant
shutdown in late spring. In addition, we need to proceed on
procurement and ground preparation as soon as possible. We gladly
offer to meet with your engineering review personnel any time at your
convenience in Raleigh if this will speed up the review process.
In case of any questions or additional needs, call me at
[phone] or, in my absence, contact John Nagle or Russell
Mc Donald at the same number.
Sincerely,
i
Thomas W. Olcott
Environmental Control
Coordinator
TWO:mm
1593M
CC: (Cover letter and design memo only)
M.J. Noland, Regional Supervisor
Dept. of Human Resources and
Community Development
Fayetteville, N.C.
DEQ-CFW 00064711