DEQ-CFW_00044272

Your Name: Bobby Nelms
Facility ID Number: NCD047368642
Facility Name: Chemours Company -Fayetteville Works
Document Group: Inspection/investigation (1) Document Type:
Date of Document:
Author(s) of Document: B2ddUNd&E
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Enforcement Date:
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Scheduled Return to Compliance: 11/9/2015 Actual Return to Compliance: ("Hc,"he tc,., a d",.' e ,
Regulation Description: 40 CFR 268.50(a)(2)(i)
Comment: dhe facility failed to mark with an accumulation start date three (3) 1-gallon containers of methylene chloride
located in the facility's permitted hazardous waste storage area.
DEQ-CFW-00044272

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DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION I
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Name of Facility: Chemours Company -Fayetteville Works
EPA ID Number: NCD 047 368 642
Type of Facility: Large Quantity Generator, Permitted Storage and
Treatment Facility
Facility Location: 22828 NC Highway 87 West, Fayetteville, NC 28306
Bladen County
Telephone Number: [phone]
2. FACILITY CONTACT: Mike Johnson, Environmental Coordinator, Chemours
Email: [e-mail]
Mike Johnson — Chemours
Dianne Fields — Waste Technology Guardian, Chemours
Danny Melvin — Distribution Safety Manager, Chemours
Crystal Simmons — HW Technician, Chemours
Laurie Benton — USEPA, Region 4
Robert K. Nelms — NCDENR, Hazardous Waste Section
4. DATE OF INSPECTION: July 21, 2015. Last inspected September 10, 2014
5. PURPOSE OF INSPECTION: Unannounced audit to determine compliance with
regulations described at 40 CFR 261, 262, 264, 265, 268, 273 and 279 and the facility's
permit.
6. FACILITY DESCRIPTION: Chemours Company -Fayetteville Works, formerly DuPont
Company manufactures fluorocarbon chemicals, resins, and intermediates including:
Polyvinyl Fluoride (PVF) which is used in the manufacture of aircraft interiors, due to its stain
resistance, and in backing for photovoltaic cells (solar panels); Polymer Processing Aid
Process (PPAP) which was the C8 manufacturing portion of the plant until April 2013 when
the C8 product was replaced with new a fluorocarbon surfactant; Nafiong membrane which
is used in fuel cells, electrochemical devices, chlor-alkali production, metal -ion recovery,
water electrolysis, plating, surface treatment of metals, batteries, sensors, Donnon dialysis
cells, drug release, gas drying or humidification; and super -acid catalysis for the production
of fine chemicals, and various fluoromonomers that either are used on -site in the production
of fluoroproducts or are shipped to off -site customers.
DEQ-CFW-00044273

Chemours Company -Fayetteville Works
CEI Report, page 2
EPA I.D. # NDC 047 368 642
The facility is a large quantity generator and holds a Part B permit for storage (in containers
and tanks) and treatment of hazardous waste. The Chemours Company facility is located on
approximately 2200 acres, 350 of which are located inside the fenced perimeter and are
dedicated to production activities.
The facility operates two 12-hour shifts making the plant manned 24/7. There are 264
Chemours Company employees and numerous contractors employed at the site. The property
has three potable wells (one operable) on site but drinking water is now supplied by the Bladen
County Water System. The site WWTP treats the water for all three entities on site. There
are 41 monitoring wells on site as well as five wells used by the NC Water Resources
Commission for collecting data on aquifer depths. An impoundment on site which is located
behind the permitted storage pad is used as a sediment basin for process river water. The
closest private residence is less than a quarter mile from the site's boundary and approximately
a half mile from operation areas. Ownership of the facility shows as The Chemours Company
FC LLC.
The DuPont Company — Fayetteville Works was split into three separate companies:
• Kuraray Americas with the Butaciteg (inner liner for automotive safety glass) and
SentryGlasg (architectural safety glass) businesses which manufactures Glass
Laminating Solutions (GLS)/Vinyls
• Performance Chemicals (Chemours) with the Fluoromonomers, Nafiong membrane,
and the Polymer Processing Aid Process whose main production consists of Flourine
chemicals which go into other Chemours products, and
• DuPont with the Polyvinyl Fluoride ("PVF") business.
Chemours is a wholly owned subsidiary of DuPont and is now the owner and operator of all
of the permitted hazardous waste units at this site, and hence is the owner of the RCRA
Hazardous Waste Management Permit which transferred and became effective on July 1,
2015.
7. WASTE STREAMS INCLUDE:
Waste F/C DO 18, D028 — Benzene and 1,2-dichloroethane
Waste H/C DOO], D003, F005 — Toluene, acetonitrile, adiponitrile, diglyme
Waste MeCl D029 — Dichloromethane and 1, 1 -dichloroethylene
A/F D002, D003 — Acid fluorides
Waste DMSO D002 — Potassium Hydroxide
Waste H2SO4 D002 — Sulfuric acid (primary waste generated)
Spent filters D007, F002 — Chromium and Trichloro-trifluoroethane
Universal waste lamps and batteries
Used Oil
Emergency Preparedness — Chemours has its own fully trained fire brigade along with
arrangements with local authorities. In the event of an emergency on the site Chemours
trained personnel are the initial responders with an option of requesting outside assistance.
DEQ-CFW-00044274

Chemours Company — Fayetteville Works
CEI Report, page 3
EPA I.D. # NDC 047 368 642
Contingency Plan — The contingency plan in the approved July 2015 RCRA permit was
reviewed.
Manifests / LDR — The last quarter of 2014 and first quarter of 2015 manifests were
reviewed. No issues were noted.
Transporters: Suttles Truck Leasing
ALD 095 704 011
Sentinel Trans.
DER 000 002 741
Robbie D. Wood
ALD 067 138 891
TSD's: DuPont Co.
NJD 002 385 730
Clean Harbors
ARD 069 748 192
Heritage
OHD 980 613 541
Tradebe
TND 000 772 186
Biennial Report — The 2013 biennial report was on site and available for inspection.
Training Records — Paul Chavis & Mike Hutto assisted us with the training records review.
No training violations were observed. Training records were reviewed for:
Shondell Davis
04/11/14
Kenneth McNeil
01/05/15
Pam Richardson
12/15/14
Tim Full
02/05/15
Kelly Scott
02/05/15
Mike Valdez
11/17/14
Michael Chavis
12/18/14
Chris Sessoms
01/06/15
Jason Page
12/15/14
Jason Brown
12/14/14
Inspection Records (storage) - The 2014 - 2015 inspection records were reviewed. The
Chemours facility is required to perform numerous inspections for RCRA compliance.
Below are the inspection records which were reviewed:
- 264.1052 — Pumps in light liquid (monthly) subpart BB
- 264.1057 — Valves in light liquid service — (monthly) subpart BB (quarterly if no
leaks detected)
- Drum Pad Inspections — Weekly (Inspected daily)
- Waste Fluorocarbon Storage Tank & Reactor — Daily
- Waste Fluorocarbon Trailer — Weekly (Inspected daily)
- AN & 14FA — H 90 day lab container — Weekly (Inspected daily)
- Fluorocarbon & Hydrocarbon 90 day lab container — Weekly (Inspected daily)(5
gallon container located inside lab)
- Polymer Container 90 day — Weekly
- Nafion MMF Reactor Neutralized tails waste tank (Interim Process) — Daily
- Waste DMSO Storage Tank — Daily
- VES Waste Fluorocarbon Storage Tank — Daily
- Nafion Waste Hydrocarbon ISO Container — Weekly
- (PPA) — 580.30 APFO Waste Sulfuric Acid Trailer — Weekly
- Waste Decant Tank & Dilution Tank- Daily (Tank has been out of service since
12/24/13 and inspections are not being conducted.)
- Subpart CC — Annual Hazardous Waste Tank Inspection - 265.1084(c)(4)
- Nafion Unheated Flammables Storage Shelter - Weekly
DEQ-CFW-00044275

Chemours Company — Fayetteville Works
CEI Report, page 4
EPA I.D. # NDC 047 368 642
Chemours identifies areas to be monitored for subparts BB & CC by "areas" listed below:
Area 41 Waste Flourocarbon
Area #2
PPA
Area #3
DMSO Heavy Liquids
Area #4
VE South
Area 95
MMF — Runs once a year for about 3 months as needed
Area 46
VE North
Area 47
Old HPFO area — Out of Service
Area #8
RSU (Rearranged Sultone)
Area #9
Out of Service
Area #10
Out of Service
Area #11
New HFPO — one tag unsafe to monitor
Accumulation Areas:
— Nafion Manufacturing Lab - LC vials were accumulated in a flammable cabinet. The
container was closed and labeled.
Also located in the lab was a five gallon container located under the hood which is used
to collect waste generated around the lab at individual work stations. This container
was properly labeled and dated with an accumulation start date. Chemours personnel
stated the container was dated because waste from satellite accumulation containers is
brought to the container and, failure to date the container would be a violation of EPA
policy due to waste being transported from satellite accumulation container to satellite
accumulation container.
I direct your attention to RCRA Online document R014703 section 11 which states in
part, ..."a single SAA [satellite accumulation area] may have multiple points of
generation. Movement or consolidation of hazardous waste within an SAA is
permissible, as long as it remains "at or near" the "point of generation" and "under the
control of the operator of the process generating the waste." The State's interpretation
of this statement is that an individual laboratory (a room not an entire building) may be
the accumulation area and waste from numerous containers can be consolidated into a
single container which is managed as a satellite accumulation container provided 55
gallons of total waste is not exceeded in the satellite area (laboratory) and the waste
that is consolidated is compatible.
Storage Areas:
The facility has the following hazardous waste storage areas:
— Nafiong Unit — The Nafiong unit has four permitted hazardous waste storage tanks.
With the exception of the 65 gallon vinyl ether south tank; which was inaccessible, all
tanks were observed to be labeled and in good condition.
— The ISO container (4,623 gallons) near vinyl ether south is a 90 day storage area. It
was properly labeled, dated and closed.
— Three drums in the polymers area are managed as a 90 day storage area. All of these
containers were properly labeled dated and closed.
DEQ-CFW-00044276

Chemours Company — Fayetteville Works
CEI Report, page 5
EPA I.D. # NDC 047 368 642
— The permitted waste storage pad was well organized. The storage pad contained
numerous pallets of containers which were properly labeled, dated, and closed. The
lab pack storage cabinets were properly labeled and closed as required by permit. Three
one gallon containers (Picture 1, below) labeled "Methylene Chloride" were observed
on the storage pad without accumulation start dates.
Picture 1: Hazardous waste containers observed in the permitted storage area labeled
"Methylene Chloride" but lacked an accumulation start date.
— PPAP Polymer Processing Aid Process (raw material for Teflon) — In this area there
were two 90 day storage tanks which are able to be viewed by camera. One tank was
located on the first floor and the other on the second floor. Neither of these tanks is
currently used for hazardous waste management and both have been cleaned.
— PPAP tanker — This container was observed during the inspection and found to be
properly labeled and dated.
— Nafion Flammable Storage Area — This storage area is located at the DuPont plant due
to a requirement of the onsite fire marshal. At the time of inspection there were four 55
gallon containers all of which were properly labeled, dated, and closed. The storage
area is located away from the main plant due to concerns with its flammability.
Universal Waste: Lamps and batteries are accumulated in a storage shed near the
permitted storage pad. At the time of inspection there were two drums present, one for
lamps and one for batteries. Very specific packaging information is posted for the lamps
though there was some discussion regarding the loose lamps observed in the drum. It was
DEQ-CFW-00044277

Chemours Company — Fayetteville Works
CEI Report, page 6
EPA I.D. # NDC 047 368 642
determined that someone had failed to follow the clear directions which were posted. No
violation will be cited for this matter.
External Condition of Facility: No adverse conditions noted.
9. WASTE MINIMIZATION: A written waste minimization plan is maintained on site.
40 CFR 268.50(a)(2)(i): An owner/operator of a hazardous waste treatment, storage or
disposal facility stores such wastes in tanks, containers, or containment buildings solely for
the purpose of the accumulation of such quantities of hazardous waste as necessary to
facilitate proper recovery, treatment, or disposal and each container is clearly marked to
identify its contents and the date each period of accumulation begins.
Chemours Company is in violation of 40 CFR 268.50(a)(2)(i) in that the facility failed to
mark with an accumulation start date three 1-gallon containers of methylene chloride waste
located in the permitted hazardous waste storage area.
0 Consider adding a space to the inspection logs for persons to print their names in case
their signature is illegible. It is important to have legible records in the event the
documentation requires any follow up by inspectors, managers, or other coworkers.
0 Modify the Subpart BB monitoring reports to make them easier to interpret.
Documented inspections prior to this year were excellent and some version of the
previous documentation should be considered. This was discussed with Dianne Fields
during the inspection.
12. CONCLUSION: Ticket NOV Docket 42015-055 will be issued for the violation noted
during this inspection.
Robert K. Nelms
Environmental Senior Specialist, NCDEQ
Emailed to Mike Johnson
Facility Representative
DATE: October 9, 2015
DATE: October 9, 2015
DEQ-CFW-00044278