DEQ-CFW_00068055

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Reeves, Gregory W
From: Michael E Johnson [[e-mail]]
Sent: Wednesday, November 16, 2011 12:17 PM
To: Reeves, Gregory W
Subject: DuPont Air Emissions Inventory Report -- Ammonia Emissions
Greg:
Per our conversation today, DAQ is questioning the over -reporting of the emissions of ammonia
from our site's wastewater treatment plant ("WWTP") as was reported in the 2010 air emissions
inventory report.
As explained in the narrative section of the WWTP (Emission Source ID No.
WTS-A) section of the report, aqueous ammonia (NH40H) is added to the WWTP as an essential
nutrient for the biological organisms. The normal addition of 69,000 lb. NH40H per year is
stoichiometrically equivalent to 20,010 lb.
NH3 per year.
The WWTP's carbonaceous bacteria would utilize some fraction of the ammonia in their
biological system, while the nitrifying bacteria would convert a large fraction of the
ammonia to nitrites and then to nitrates.
However, we have no data on the WWTP effluent (monitored as Outfall 001 via our NPDES Permit)
that would allow us to attempt any engineering calculations to estimate the actual emissions
of ammonia. We do measure Total Nitrogen at our final effluent (Outfall 002), of which the
WWTP discharge represents only 8% of that flow.
Since we are not able to confidently report to DAQ what might be the true emission of ammonia
and could not substantiate any calculated quantity, we elected to conservatively report the
worst -case scenario whereby all the aqueous ammonia added to the WWTP is emitted as the molar
equivalency of anhydrous ammonia. This approach gives both DuPont and DAQ complete assurance
that the ammonia emissions were not under -reported.
Michael E. Johnson
Environmental Manager
DuPont Company
Fayetteville Works
[phone]
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