DEQ-CFW_00076491

I
s
I
I
NPDES WASTE LOAD ALLOCATION g'gineer Date Pec
Facility Name: �E ti;_ s T l' c. [ ) - Date ` j •
Existing 0 ?T dle1CP'E-ASt0 ;4'i2CVi.G teC;: TC:<8`i-r FDA i-1
_ Pipe .. >� Proposed OPermit No.. �L
1
Design Capacity (MGD) : d Industrial (% of Flow) : Domestic (% of Flow)
Receiving Stream: Class: Sub -Basin:
Reference USGS Quad: { (Please attach) Requestor: Regional Office --, %
(Guideline limitations, if applicable, are to be listed on the back of this form.)
Design Temp.: Drainage Area (mi2): Avg. Streamflow (cfs):
7Q10 (cfs)
Winter 7Q10 (cfs) 30Q2 (cfs)
Location of D.O. minimum (miles below outfall): Slope (fpm)
Velocity (fps) :
K1 (base per day): K2 (base e. per day):
Effluent
Characteristics
Monthly
Average
Comments
%` 3 ibsId
6-
�� :
e
o�04-
S_85/
Effluent
Characteristics
.'z)ntnly
i_verage
Comments
s
1
erCt v;*
Original Aflocaiion O comments: � J� ��' "Q ^° ""u"' ,�lKG , or CA-da�r
Revised Allocation
0 A --
be •10 Ups �Cnc�L�`�`� 50�ic/5 0 Visi4 le 1r�a�
Confirmation O �� p.t`(�.�.r �.�,aw c✓YS +
Prepared By: Reviewed By: i���c !' %` Date:
�' Cwc c �a-c yi�t tJk c ! 0 ✓' '�j n t, �' [ J too lee 4.0

For Apgopriate .0isdorAers, list Complete Guideline Limitations Now
Effluent Mc)nthly Maximum Daily
Characteristics Average I Average I Cbmments
Type.of Product Produced Lbs jDay Produced Eff1idrit Guideline :.Reference
a

Request No. :3335
--------------------- WASTELOAD ALLOCATION APPROVAL FORM ---------------------
Facility Name
Type of Waste
Status
Receiving Stream
Stream Class
Subbasin
County
Regional Office
Requestor
Date of Request
Quad
: E. I. DUPONT DE NEMOURS & CO, INC
: PIPE 002, INDUSTRIAL Ex
��p � ���
: EXISTING `--
: CAPE FEAR RIVER
ENV. MANAGEMENT
: � -�-..
8���ETTE�M������| ������
: 030616 �' --^^~~~' ~~'`'�~
: BLADEN
: FAYETTEVILLE Drainage Area (sq mi> :
: S. BRIDGES Summer 7010 (cfs) : 819.
: 6-30-86 Winter 7010 (cfs) : 1000.
: H 23 Average Flow (cfs) :
... ..... ..... ..... -..... ..... ..... ..... ..... .... ... ----..... ..... ... .... ..... ---- RECOMMENDED EFFLUENT LIMITS -------------------------
Wasteflow
Fluoride
Temperature
pH
:
(mgd): 11.4
(lbs/day): 7663
: *
(SU): 6-9
:
:
:
:
:
:
�. `��
-�A eze_ xxw*^«� CLO�
. �
U �
e- 00o_ `
�
------..... ..... .... .... -----.... ..... .... .... ..... .... ..... ------------ COMMENTS ----------------------------------
* THE TEMPERATURE OF THE EFFLUENT SHALL BE SUCH AS NOT TO CAUSE AN INCREASE
IN THE TEMPERATURE OF THE RECEIVING STREAM OF MORE THAN 2.8 C AND IN NO CASE
CAUSE THE AMBIENT WATER TEMPERATURE TO EXCEED 32 C.
THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE COOLING WATER.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN
TRACE AMOUNTS.
FACILITY SHOULD SELF -MONITOR FOR TRIFLUOROACETATE.
�������..... ... ������..... ..... ��..... ..... ..... ... �.... ..... ..... ..... ..... ..... .... ..... .... .... ... ���..... ..... ..... ... ..... ..... ..... ..... ����..... ..... ��.... ..... �..... ..... �..... ..... ��..... ..... �..... ..... ��..... ..... .... ... �.....
Recommended by
Reviewed by:
Tech. Support Supervisor _ __
Regional Supervisor _/� �.�__..... .....
�
Date
Date
Date _ ___

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DEQ-CFW 00076494

•. �i14 REV. 12-79
' oUPONT
ESTABUSNED1802
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, di-scussions 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 hexafluoropropylene (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 4.0 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 obtai-ned 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 00076495

' T
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
�PIP
Thomas W. Olcott
Environmental Control
Coordinator
[phone],
TWO:mm
1665M
h'
DEQ-CFW 00076496

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 <0.1
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 Bladen-Cumberland County line
per information from Fayetteville Regional Office
TWO:mm
1665M
DEQ-CFW 00076497

f
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 \\
(/Vb coo,."Uc' W'ini- - Dj/_t ;bN)
52 p m Fluoride, 65 p m Trifluoroacetate
�5tudy initiated/Completed
7-1 /13/84-11 /1 5/84
48-HOUR EG50** TO DAPHNIA .MAGNA
Summary, Unchlorinated mix wastewater exhibited very low acute toxicity to
Daphnia magna..under static unaerated test conditions during a 48-hour
exposure period. There was 20,55 mortality in the 100% waste concentration and
0% mortality in the 759a concentration.
Objective; To determine the acute toxicity of the test material to a
macroinvertebrate Daphnis magna,
Procedure-. The test material, as received was diluted with laboratory mass
•culture we11 water to yield thb desired exposure concentrations. After
mixing, 200 mf- aliquots of each concentration were introduced into each of
two separate 250 mL glass exposure vessels. Two identical vessels containing
only laboratory m ass 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 00076498

14
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 t•emperut'ure was
maintained between 19.6 and 20.0°C. Photoperiod was maintained at 16 hours
light:8 Hours dark.
Immobility counts and observations were made at 24 and 413 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 wero measured•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 magna sxpDsBd ID unchlorinaL•ed rni.x
wastewater are presented in Table I, The 4B—bnur FT5D was riot calculated
because the result would show >1000.
The cheminnl anti physical parameters measured during the test are reported in
Tail -U. All wens milhin acceptable ranges fnr this study.
Synonyms: UnchlorinaLad mix wastewigher
EC50 = The concentration which causes immobility to 50% of a test
populatiun during the specified time period.
DEQ-CFW 00076499

.l 1
Report by: ' -i . l �V''��•%
James W. Wetz 1
Technician
. 4
Approved by 1
Study Director:
David G. Hutton
Consultant, Environmental Sciences
Approved by; �{� t/. ,Cc.� tC.Ct ••fr1
r.ara1. 1). P/Itchfi elrl
$BL''t-Im Supervis=2 Env-.rDT rental Btloiogy
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-
L •
DEQ-CFW 00076500

TABLE 1
RESULTS OF A 48-HOUR ACUTE TOXICITY TL"S(
WITH DAPHNIA MAGNA EXPOSED TO A-104. (MR 7377-001)
Nominal Test Observed Immobility W
Concentrations 24 Hours 48 Hours
(9b ) A* g* A* p
100' - 0 0 40 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 0 0 D 0
1 0 0 U 0 :
0.1 0 0 0 0
ti2a ContTai 0 0 D 0
Replicatz ax.pasure chambers -c9ntei-ring ten daphnids -e-ach.
-4-
DEQ-CFW 00076501

TABLE II
RESULTS OF PHYSICAL AND CHEMICAL
PARAMETERS
MEASURED DURING
A 48-HOUR ACUTE TOXICITY TEST
WITH DAPHNIA MAGNA
EXPOSED TO A-104.
(MR 7377-001)
Nominal Test
Control
100
24
0.1
Concentrations N) (High)
(Medium)
(Low)
H20
Dissolved Oxygen
(mg/L)
0 Hr.
8.1
8.4
6.4
8.6
24 Hr.
7.5
8.2
8.4
8.4
48 Hr.
6.8
7.9
8.2
8.2
•�
11 Hr.
7.7
.8.4
B-3
B.b
24 Hr.
8.0
8.3
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
(mg/L as CaCO3—))
• 0 Hr.
28
75
90
90
Conductivity (pnhos/cm)
0 Hr.
2200
800
195
190
- 5 -
DEQ-CFW 00076502

ATTACIiMENT 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. inix
(No Coat tm(r W4n5r4_ PA(MOU)
52 ppm Fluoride, 65 ppm Trifluoroacetate
Study Initiated/Completed
il/12Jf34-11J1bJ�34 •
96-HOUR LC50** TO BLUEGILL BUNF M
Suwary. Unchlorinated mix wastewater was not acutely toxic to bluegill
sunfish under static, unaerated test conditions during a 96-hour exposure
period.
Objective: To detexmine tine acute toxicity of the test material to a warm
freshwater fish.
Procedure: The test material, in original form, was introduced into
commercial, glass, rectangular 5 1/2-gallon aquaria and diluted with
laboratory well water to yield the desired exposure concentrations in 15
ifter" final voluues. An identical vessel containing only laboratory well
water was desiUnatod 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 00076503

Ten juvenile, unsexed bluegill sunfish (Lepomis macrochirus) fron 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. Bluegill sunfish are identified by
labeling the culture and test vessels. Fish were not fed for 48 fours prior
to or during the exposure. The test- solutions were riot- aerated and
temperature was maintained at 22°C. Photoperiod was maintained at 16 hours
light: 8 hours dark. Mortality counts and observations were made every 24
hours during the 96-hour exposure period.
Dissolved*'Oxygen was measured in the control, low, mediun, 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, medium, and high test concentrations.
-All rsrords from this test will be maintained at Baske].1 laboratory Lor
'2=icology and Industrial Medicine or at the Du Font Hail of Tacords.
Results: Test razijlts fnr bluegill sunfish are presented in Table 1,
Unchlorinated 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 test-, reported
in Fable II, were all within acceptable ranges.
* S non s Dnchlorinated mix wastewater
** L,C50 = The concentration which is lethal to 50% of a test population
during the specified time period.
- 2 -
DEQ-CFW 00076504

A
Report by: �CGIJ(� .� �C> /�C•• /
Charles L. Hall
Technician
. 4
Approved by
Study Director: ,,D��.i�� ,1%• f���:`
David G. Hut -ton
Consultant, Envirorunental Sciences
Approved by:
• Carol, D..Li • eld
spnt i na Rupeivi— nmental Biology
Date 'Issued: Novamber 29, 1984
Haskell Lab Report No. 522-84
There are 5 pages in this report.
3
DEQ-CFW 00076505

TABLE, I
RESUlfrS OF A 96-HOUR ACUTE TOXICI`1'Y TEST
WITH
BLUEGILL SUNFISH
EXPOSED TO A-104. (MR 7377-001)
Nominal Test
Concentrations
Observed
Mortality (a)•
()
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
D
D
0
1
fl
0
D
0
0.1
0
0
D
0
H2O Control
D
D
D
.D
M
DEQ-CFW 00076506

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)
Ncsninal Test
100%
42%
0.1%
Control
Concentrations
(High)
(Medium)
-(Low)
H0_
Dissolved 0xygen
(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
V
0 Br.
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
96 Hr.
7.5
7.4
7.2
7.1
Total Alkalinity
(mg/L as CaCO
0 Hr.
.120
96
78
81
EDTA Hardness (mg/L as Cam
0 Hr. 69 76 73 74
Conductivity (umhos/cm)
0 Hr. 420 273 170 165
- 5 -
DEQ-CFW 00076507