DEQ-CFW_00046254

Hazardous Waste Section
1. Identification. Fill outform completely and accurately before sending it to File Room
Print Your Name Above (Last, Firs})
N C D 0 4 7 3 6 8 6 4 2
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DuPont Fayetteville
Facility Name
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11. Document Type:
ffimmk check oep M-M
General (G)
Document Type below
Permit (P)
Corrective Action (CA)
0 Compliance Assistance Visit (CAV)
Ll Alternative to Post -Closure Permit (APQ
F1 Confirmatory Sampling (CS)
Fees/invoices (F)
F1 Emergency Permit (EMP)
Ll Corrective Action Information (CAI)
01 Hazardous Waste Report (HWR)
Ll Modification (MOD)
1-1 Corrective Measure Plan/Design (CMPD)
❑ Notification 8700 (8700)
El Notice of Deficiency (NOD)
Ll Corrective Measures Study (CMS)
Technical Assistance (TA)
11 Environmental Indicators (EI)
_1Correspondence (C)
Ll HSWA Remedy (HSWA)
11 Other (0)
�n PI)
F1 Interim Measures Study/Plan/Implemented (IM)
Closure (C)
11 Correspondence (C)
11 Land Use Restriction, Institutional Controls (LUI.)
Ll Closure Information (CI)
11 Other (0)
El RCRA Facility Assessment (RFA)
11 Closure Plan (CP)
Groundwater (GW)
Ll RCRA Facility Investigation (RFI)
11 Closure Report/Certification (CR)
11 Comprehensive Monitoring Event (CME)
11 Remediation System Effective Reports (RSER)
D Correspondence (C)
El Groundwater Monitoring Report (GMR)
F1 Correspondence (C)
D Other (0)
Ll Correspondence (C)
Li Other (0)
Inspection/investigation (1)
11 Other (0)
Enforcement (E)
El Case Development Inspections (CDI)
Financial (F)
L Administrative Order on Consent (AOC)
D Complaint Investigation (CMP)
D Balance sheets (BS)
E Compliance Order (CO)
Ll Compliance Evaluation Inspection (CEI)
F1 Financial record review (FRR)
D Enforcement Package (EP)
iEl Compliance Schedule Evaluation (CSE)
L1 Financial statements (FS)
7 Immediate Action Notice of Violation (IANOV)
11 Emergency Response (EMR)
El Insurances (1)
D Notice of Violation (NOV)
E Focused Compliance Inspection (FCI)
El Mechanisms and instruments (MI)
E Settlement Agreement (SA)
Ll Sampling Event (SPQ
11 Tax returns (TR)
11 Ticket Notice of Violation (TNOV)
..................... .
. .
E Correspondence (C)
F1 Correspondence (C)
F_ Correspondence (C)
El Other (0)
0 Other (0)
L—J Other (0)
Ill. Description:
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IV. DateofDocument: Date when the document generated, the date typed or printed on the front page of document
Date on Document 02 24 2011
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Date Received
Date Scanned
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Hazardous Waste Section Updated: 1110312010 File Room Document Transmittal Sheet (Form: LK-600)
DEQ-CFW-00046254

DuPont Fluoroproducts
QW. 22828 NC Highway 87 W
Fayetteville, NC 28306-7332
Mr. Carl Utterback
Hazardous Waste Section
NCDENR — Division of Waste Management
401 Oberlin Road — Suite 150
Raleigh, NC 27605-1350
Subject: Responses to First Notice of Deficiency — Submission No. I
RCRA Hazardous Waste Management Pen -nit Renewal Application
DuPont Company — Fayetteville Works
Pen -nit No. NCD 047 368 642
Dear Mr. Utterback:
Enclosed are the partial responses to the subject First Notice of Deficiency.
The outstanding items will be sent to you in a future submission. As such, DuPont is requesting
a 45-day extension for the submission of the rest of the responses and revisions.
The First Notice of Deficiency items addressed in this letter are listed below with DuPont's
response in bold type.
Section A
HAZARDOUS WASTE PERMIT INFORMATION FORM
1) The forms for the Part A [EPA Form 8700-23, November 2009] have been revised.
DuPont -Fayetteville should take this opportunity to update any facility information that
may have changed and use the new farms available online.
ME=
2) For items 11 and 12, please provide copies of the maps and drawings needed in the Part A,
or at a minimum reference their location on the Part A form under the headings for "Map"
E.I. du Pont de Nemours and Company
DEQ-CFW-00046255

Mr. Carl Utterback
NCDENR — Hazardous Waste Section
February 24, 2011
Page 2 of 4
and "Facility Drawing." The legal boundaries of the facility will need to be provided both
graphically and as a metes and bounds description.
The location of the maps and drawings needed in the Part A is referenced on the Part
A form. Attachment B-1, which is a metes and bounds description of the property
boundary of the DuPont Company — Fayetteville Works, has been added to the end of
Section B. Figure B-6, which graphically shows the legal property boundary of the
DuPont Company — Fayetteville Works, has been added to the end of Section B.
3) For item 13 "Photographs," please provide process codes (i.e., S01, S02, T01) on the labels
for the units as well as approximate dates"the photographs were taken. In addition DuPont -
Fayetteville should include a reference to the location of the photographs under item 13.
The process codes for each of the permitted units and the approximate dates of the
photographs have been added to the photographs in Section A.
Section B-1
General Description
4) Paragraph one of Section B-1 of the permit application states that DuPont -Fayetteville
conducts on -site disposal of hazardous waste. However, the HWS is not aware of any on -
site hazardous waste disposal units. Please clarify the sentence in Section B-1 of the permit
application that indicates DuPont -Fayetteville is an on -site disposer of hazardous waste.
Paragraph one of Section B-1 of the permit application has been corrected to reflect
that the DuPont Company — Fayetteville Works does not conduct any on -site disposal
of hazardous waste. The site is limited to hazardous waste treatment and storage.
Section B-2a
General Requirements
5) A map that shows the legal property boundary should be part of the permit application.
Figure B-6, which graphically shows the legal property boundary of the DuPont
Company — Fayetteville Works, has been added to the end of Section B.
6) Unless recently abandoned, potable water for DuPont-Fayetteville's Employee Recreation
Center is obtained from an on -site well. This well and other wells that supply (or supplied)
water to the DuPont facility, even if formally abandoned, should be listed in the permit
application. Information such as construction details and pumping rate (gallons per minute)
should also be included in the application. In addition, private wells located within 1000
feet of the facility should be displayed on a map.
Information concerning the DuPont Company — Fayetteville Works' two inactive
groundwater production wells within the fenced manufacturing facility and the one
DEQ-CFW-00046256

Mr. Carl Utterback Page 3 of 4
NCDENR — Hazardous Waste Section
February 24, 2011
I . 0 1 1 1 0 1 . . 0 . . , a
In, I I f M
Section B-4c
Additional North Carolina Location Standards
7) DuPont -Fayetteville should note the surface water class designation(s) of surface water
bodies located on or adjacent to facility property. The term "surface water class
designation(s)" refers to those classes promulgated by the NC Division of Water Quality.
facility property Cape Fear Ikiver have been added to Section B-4c.
Section C-1
Waste Identification and Management
8) DuPont -Fayetteville supplies information on each of the waste streams, but a table linking
all the waste streams to associate waste codes (DO01, D002, etc) and process codes (SO1,
SOI, T01) and unit names (container area or tank) would be very helpful. For example:
---- ------------------- Hazardous Waste
Hazardous
Process
Waste Stream
Unit Name
Waste Code
Code(s)
Waste DMSO
1
- ------------------------------------- - -------------- - ------
- i
Storage Tank
®
Table C-1, which provides the requested information, has been added to the end of
Secti1,(1 C.
Section C-ic(2)
Tanks
9) Please provide clarification that the Waste DMSO is a D002 corrosive waste in the
description of the Waste DMSO Storage Tank on page C- 10.
Section C-3
Sampling Procedures
10) On page C-15 DuPont -Fayetteville refers to "transferring a Waste Fluorocarbon Reactor
batch to the trailer" and on page C-17 DuPont -Fayetteville refers to the "transfer line to the
Waste APFO Sulfuric Acid tank track," but further descriptions of "the trailer" or the "tank
DEQ-CFW-00046257

Mr. Carl Utterback Page 4 of 4
NCDENR — Hazardous Waste Section
February 24, 2011
truck" were not found in Section C. Please clarify the movement of each waste stream
from generation to treatment, storage and/or off -site disposal.
Both referenced sections have been modified to clarify the movement of each waste
stream.
Section D- I
Container Storage Area
11) Please provide a drawing of the container storage area with a general layout of the locations
of the maximum number of drums/pallets, the trenches, sump and piping to "non -contact
cooling water ditch," emergency equipment, etc.
Figure D-4, which graphically shows a general layout of the Container Storage Area,
has been added to the end of Section D.
Section E-2
General ffydrologic--Infonnation
12) In order to document the hydrogeologic system discussed in Section E-2, DuPont -
Fayetteville should include a site -wide potentiometric map in the permit application. A
brief historical overview of the groundwater investigations that have been conducted at the
facility should accompany the map.
Figure E-1, which is a site -wide potentiometric map, has been added to the end of
Section E. In addition, an entire Section E, including a brief historical overview of the
groundwater investigations, is being submitted to include the original submission date
and the current revision date in the footer of that section.
If you have any questions regarding this submittal, plea— onnt-4 me nt (Q1 0) 679-1155
Environmental Manager
Enclosures
DEQ-CFW-00046258