DEQ-CFW_00080925

DIVISION OF WATER QUALITY
January 15, 2002
MEMORANDUM
TO: David Goodrich, Supervisor
NPDES Perrnitting and. Engineering Unit
FROM: Grady,,Dop�on,.Ei-tvii-om-nenta-I Engineer
eville , fegional Office
Faye4
""V
THROUGH: Paul RaJ�,x.J%.Water Quality Regional Supervisor
SUBJECT: Renewal ofNPDES Permit
E.I. DuPont de Nernours & co., Inc., Fayetteville Works (near Duart)
NPDES Permit No, NCO03 5 73
Bladen County
Please find enclosed the staff report and recommendations of the Fayetteville Regional
Office concerning the renewal of subject NPDES Permit.
If you have any questions or require any further information, please advise.
PER:GD/bs
Enclosure
cc: Kitty Kramer
DEQ-CFW-00080925

SOC PRIORITY PROJECT: YES NO X_
If Yes, SOC No.
To: NPDES Permits and Engineering Unit
Water Quality Section
Attention: Mike Te leton
it-j- mp.
Date: Jannary 15,2002
NP'DES STAFF REPORT ANTI) RECOMMENDATION
COUNTY- Bladen
Permit No. NC-QO03573
PAIrr I - GENERAL INFORMATION
1, Facility and Address: E.1, DuPont de Nemours & Co., Inc.
22828 NC Highway 87 W
Fayetteville, NC 28306
2.
3
4.
Date of Investigation: November 19,2001
eport Prepared by: Grady Dobson, Environmental Engineer, FRO
Persons Contacted and Telephone Number., Michael Johnson, Environmental Coordinator
E.I. DuPont, Fayetteville Works
910-678-1155
Mr. Robert Geddie, ORC
910-678-1219
5. Directions to Site: This facility is located at the Bladen-Cumberland County line, between
Highway 87 and the Cape Fear River,
6. Discharge Points), List for all discharge points:
Latitude: 34'49'52" Longitude: 78'49'00"
Attach a USGS map extract and indicate treatment facility site and discharge point on niap.
U.S.G,S. map excerpt indicating treatment facility site and discharge point attached.
U.S.G.S. Quad No. H 23-SE- t.J,S.G,S. Quad Name: Duart-_NC
7. Site size and expansion area consistent with application? X Yes — No
DuPont owns approximately 2,600 acres at this site,
8. Topography and relationship to flood plain: Relatively flat,
9. Location of nearest dwelling: None within 1,000 -feet
If No, explain,
DEQ-CFW-00080926

PART I - GENE10L INFORMATION (continued)
10, Receiving stream or affected surface waters: Cape Fear Itiver,
a. Classification-. C
b. River Basin and Subbasin No,: 03-06-16
0. Describe receiving stream features and pertinent downstream uses:
The combined waste discharge fi-orn this facility flow is a wood lined
channel installed as an effluent and storm water conveyance. This
combined flow discharges over a fabri-formed concrete lined ditch until
velocities are diminished and thence to the remainder of the effluent
channel. Under normal (dry) conditions, this facility produces the flow
in the effluent channel, The Cape Fear Itiver is located approximately
2,500 feet downstream, (The discharge point has historically been
indicated as the main stem of the Cape Fear River.)
PART 11 - DESCRIPTION OF WASTES AND TREXrMENT WORKS
Volume of wastewater to be permitted: n -10 -MGD (Ultirnate Desig Capacity) of the
treatment plant, discharge point 001. A separate discharge (002) is not flow limited.
b. What is the current permitted capacity of the Wastewater Treatment facility? 2,0 --iN4GD
C. Actual treatment capacity of the current facility (current design capacity). 1.0 -N4QjD
d. Date(s) and construction activities allowed by previous Authorizations to Construct
issued in the previous two (2) years. N/A
C. The existing or substantially constructed wastewater treatment facilities:
Process wastewater and stromwater from the various manufacturing
areas are collected in the respective area sumps and ultimately conveyed
via a gravity flow underground process sewer pipe to the site's central
wastewater treatment plant (WWTP). Sanitary sewage is conveyed via a
separate underground sewer system to the WWTP. The permitted
flowrate of the WWIT is 10 MGD, with an actual average flowrate of
approximately one (1) MGD.
This untreated wastewater is commingled in the WWTII Influent Sump
where it is pumped to an 850,000-gallon Equalization Basin. The
Equalization Basin is mixed with two floating mixers, Three (3) floating
surface aerators in the basin cool and aerate the incoming wastewater.
DEQ-CFW-00080927

PART11 - DESCRIPTION OF WASTES AND 'I'REATmENT WORKS (continued)
A 175,000-gallon Emergency Retention Tank is available for temporary
storage of unsuitable wastewater. This unsuitable wastewater, which
typically exhibit a high organic loading or a chemical to which the
WWTP activated sludge is not acclimated, is eirentually treated in the
WWTP at a rate that allows for proper biological treatment.
Wastewater from the Equalization Basin is pumped to a 250,000-gallon
PredigesterTank in which initial biological activity with the WWTP
activated sludge begins, The Predigester Tank is aerated with both a
floating surface aerator and diffused air. Tlie partially treated
wastewater from the Predigester Tank is PLImped to a 1,700,00-gallon
Aeration Tank.
The Aeration Tank is the site of the majority of the biological activity,
The Aeration Tank is aerated by both a diffused air system located in the
bottom of the tank, and by a floating Biomixerg that injects air through
submerged rotors.
The biologically treated waste -water is then sent to two (2) in -ground
I
clarifiers (I 19,000-gallons and 168,000-gallons respectively) in parallel.
The clarified treated effluent is discharged to and through Outfall 001.
The wasted sludge is sent to a Dissolved Air Flotation (DAF) unit, then
to a 47,000-gallon Sludge Storage Tank, and finally to a Rotary Filter
for thickening. The thickened sludge is dewatered in a Screw Press, and
then dried in a steam -heated dryer. The dried sludge is transported off -
site to a commercial landfill,
Non -contact process cooling water and non -process stormwater are
conveyed via surface ditches to the site's Woodlined Ditch. In addition,
excess river water flow and Outfall 001 effluent are discharged directly
to the Woodlined Ditch. The combined, total flow of water from the site
is discharged and :monitored at Outfall 002, The Outfall 002 flow
averaged 14.5 MGD during the period from 1996 to 2000, (See attached
for Outfall Numberina Scheme for new NPDES Permit.)
f. Please provide a description of proposed wastewater treatment facilities:
None anticipated
Possible toxic impacts to surface waters: N/A
h. Pretreatment Program (POTWs only): N/A ,
In development _ Approved -
Should be required Not needed
DEQ-CFW-00080928

PART' II - DESCRIPTION OF WASTES AND TREATMENT WORKS (Confinued)
2, Residuals handling and utilizing/disposal scheme,
a. If residuals are being land applied, please specify DWQ Permit No.
Residual Contractor:
Telephone: N/A
b. Residuals stabilization: PSRP PFRP- Other
C, Landfill:
The dried sludge produced at this facility is shipped to Waste Industries,
Inc., Subtitle D landfill located east of Roseboro in Sampson County
(see Sludge Management Plan).
d. Other disposalhitilization scheme (specify):
3. Treatment plant classification {attach completed rating sheet): Class III
4. SICCode(s): 2821, 2869, 3083, 3081, 4939
Wastewater Code(s) of actual wastewater, not particular facilities; i.e., non -contact cooling water
discharge from a metal plating company would be 14, not 56,
Primary 14 - Secondaiy-12 02 36
Main Treatment Unit Code: —0 5 0 0 1
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? N/A
2. Special monitoring or limitations (including toxicity) requests: None
3. Important SOC, JOC, or Compliance Schedule Dates (please attach):
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options
available? Please provide regional perspective for each option evaluated.
Saray 1[ijjgqdM: Not practical
Connection to Re go, zonal.S�ewer System: Not available
Subsurface: Not practical
Other disposal motions: None laiown
DEQ-CFW-00080929

. PART III - OTHER PERTINENT INFORMATION (Continued)
5. Other Special Items:
Please find attached photos of the discharges from the various manufacturing facilities on the
DuPont complex. All discharges ultimately go into the Woodlined Ditch which collectively
discharge into an effluent channel that discharges to the Cape Fear River.
As you may recall, the Fayetteville Regional Officewas notified by DuPont staff that high levels
of turbidity was observed entering the Cape Fear River during September 1999. That
notification resulted in an onsite visit by Ricky Revels of the FRO, That visit did reveal that
areas of the effluent channel had eroded and some channel walls were vertical. During this
period of time, the Lock Master at the US Army Corps of Engineers, Lock Nurriber 3, also
contacted the Fayetteville Regional Office to report that an. extreme amount of sediment and
turbid water were entering the River from this point,
This office requests that DuPont. provide to the Division a definite plan of action (to be
incorporated into this permit or other administrative mechanism) to address this issue. Based on
the attached letter forwarded to David Goodrich dated October 20, 2000, the Company asked
"the Division of Water Quality to take the needed steps to perform the necessary modeling to
determine what, if any, changes -would occur to the DuPont7lTayetteville Works NPDES Permit
should the final effluent be discharged upstream of Lock and Dam #3." This office has no other
information about this sediment problem,
It is apparent that the Corapany a6mowledges that their effluent channel has and continues to
cause sediment to be deposited into the Cape Fear River and is willing to address this issue. This
is a very significant matter as the Company has benefited from this effluent channel for some
years and needs to address this issue LVOON.
Also find attached recent pictures of the Cape Fear River showing the huge amount of sediment
in the River channel estimated to be 75% of the channel'"ridth at this location.
Further, this office has discussed with Mike Johnson an incident that was observed last summer
at the effluent channel and River confluence. While fishing, Paul Rawls, of the FRO, observed a
very young child sitting in the effluent channel playing. The area of the confluence is a local
fishing area that citizens stand to fish "off of the bank". Staff has observed, oil numerous
occasions, citizens standing in the effluent channel and sediment delta fishing. We understand
that this may be a unique request but we feel strongly in requesting that the Company post signs
notifying
ioti ying the public of the effluent channel. We feel that DENIR should make the public aware
that this is not a stream but an effluent channel and is not intended to be used for primary and
secondary recreation.
You may be aware of the incident that occurred with the permittee during 2001. Very briefly,
the facility discovered the presence of hexafluoroacetone hydrate (HFA) in the WWTP effluent.
1-117A, based on conversations with DuPont staff, was believed to be generated and destroyed in
the production process and based on all theory was not to make it to the WW'IT or the outfall.
Again, based on self reporting and monitoring performed by the permittee, this compound did.
make it to the effluent and DuPont, in a very timely manner, notified the regional office and
began emergency action to modify its treatment system to address this issue. As understood,
HFA is an intermediate that is formed in the NAFION process.
This matter is brought forth in this report to address and ask for clarification of Part III C. of the
NPDES Permit. This portion of the Permit requires the permittee to "notify the Permit Issuing
Authority as soon as it knows or has reason to believe" any toxic pollutant which is not limited in
the Permit will exceed various thresholds outlined in the Permit. During this emergency event, it
became apparent to this office that various processes and interaction of processes at the
DEQ-CFW-00080930

PART III - OTHER PERTYNLIENT INFORMATION (continued)
DuPont facility have the potential to generate toxic compounds not listed in the Permit. Based
on inquiries of DWQ Central Office staff and others, these compounds cannot be readily tested
for and reference material on these compounds is not easily acquired.
It is understood that the permIttee has requested of the Central Office clarification on Part III C
as to when notification is appropriate. Specifically, we ask, is reporting necessary under this Part
III C when it is "Calculated" that there is a reasonable potential for a toxic compound to be
present in the waste stream or should the permittee report confirmed measured levels of toxic
compounds that may not be listed in the Permit? This question is important because some
compounds can only (to our knowledge) be detected with analytical procedures developed by
DuPont and even then can only be measured down to the parts per million level.
We request that this issue be outlined in the cover letter of the new Permit or in a separate letter
forwarded from the Central Office (if not previously forwarded to the peirnittee) to officially
address the question. and enable this office to better enforce the -NPDES Permit.
`11iis matter is of particular importance when considering the complex nature of the wastestream
and various uses of the Cape Fear River,
PART IV - EVALUATION ANI)RECOMMENDATIONS
It is the recommendation of this office that NTC0003573 be reissued in keeping with basinwide strategy,
provided all concerns have been satisfactorily addressed,
Water Quality Regional Supervisor
— 16n
Date
DEQ-CFW-00080931

DEQ-CFW 00080934

S£602000 M=10-034

DEQ-CFW 00080936

0
09
At. discharge into
Cape Fear River
..........
. . . . . . . . . . .

DEQ-CFW-00080942

Delta (sediment) formed into
Cape Fear River at discharge plaint
(Delta 'tames rrp approximately 75%
of River in this location)
0
r'
6
n
Io
0
0
00
0
cm