DEQ-CFW_00076595

• Biennial Report for APFO Manufacture ,
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 1 of 11
July 25, 2006
LETTER OF INTENT SUBMISSION
Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
E.I. du Pont de Nemours and Company
Fayetteville Works Site
Bladen County, North Carolina
Note: The information contained in this document is submitted voluntarily and may be subject to future revision
and/or modification.
CONFIDENTIAL BL-SINESS LN'FORMATION IS BRACKETED
This report is submitted pursuant to commitments made by E.I. du Pont de Nemours and
Company (DuPont) in a March 14, 2003, Letter of Intent (LOI) to Stephen L. Johnson, Assistant
Administrator, United States Environmental Protection Agency (EPA), entitled "Voluntary
Actions to Evaluate and Control Emissions of Ammonium Perfluorooctanoate (APFO)".
Pursuant to Addendum III, provision 5, of this LOI, a facility manufacturing APFO will,
beginning in the year after production commences, and continuing for five consecutive years
following, for the prior calendar year, report to EPA biennially the following information on a
calendar year basis:
1. Annual production volume of APFO;
2. Emissions per facility (air, water, waste);
3. Summary report of groundwater monitoring results;
4. Summary report of surface water monitoring results;
5. Workplace industrial hygiene monitoring; and
6. Summary data on employee blood monitoring results.
This report provides the above information for calendar years 2004 and 2005, and includes data
received as of May 15, 2006, for the Fayetteville Works site ("the site").
General Facility Information
Company Name: E. I. du Pont de Nemours and Company
Site Location: Site where APFO is manufactured:
DuPont Company — Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
Contains Confidential Business Information
DEQ-CFW 00076595

• Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 2 of 11
July 25, 2006
1. Annual production volume of APFO
The following table shows the total production volume of APFO for calendar years 2004
and 2005.
Calendar Year APFO Production
2004 Confidential
Business
2005 Information
2. Emission per facility (air, water, waste)
For air emissions, the quantity of APFO emitted to the atmosphere in 2004 and 2005 from
the site was estimated using engineering calculations.
For surface water emissions, annually a sample of the site's final surface water discharge to
the Cape Fear River is tested for the presence of APFO1. For 2004 and 2005, results
showed APFO to be less than the analytical method's quantification limit of 0.050 µg/L
(0.050 parts per billion). The reported emissions were calculated using this analytical result
(<0.050 µg/L) and the average discharge flow rate (12.397 million gallons per day in 2004
and 10.441 million gallons per day in 2005).
The waste emissions are the quantities of APFO, on a dry basis, that are estimated to have
been present in the various solid waste streams transferred from the Fayetteville Works site.
The following table gives the estimated emissions of APFO to specific media from the
Fayetteville Works during the subject years:
Media
2004
2005
Air
47.3 lb.
55.5 lb.
Water
<1.9 lb.
<1.6 lb.
Waste
9,914 lb.
10,019 lb.
3. Summary report of groundwater monitoring results
In 2004, 2005, and 2006, the Fayetteville Works site continued the annual groundwater
monitoring for APFO that began in 2003. The monitoring involved both newly installed
wells and existing monitoring wells. All groundwater and surface water concentrations are
reported as APFO (see footnote 1 on this page). This report also provides results available
as of May 30, 2006.
While APFO is the substance manufactured at the facility, the substance measured by analytical techniques is the
perfluorooctanoate anion (PFO-). The commercial laboratory converts this analytical result to an APFO value via
molecular weight calculations. For consistency with the previously submitted biennial report for this site, results
are reported as the calculated APFO values.
Contains Confidential Business Information
DEQ-CFW 00076596

Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 3 of 11
July 25, 2006
The following table reports the groundwater monitoring analytical results, both onsite and
offsite, for 2004, 2005, and year-to-date 2006:
Summary of Groundwater Analytical Results
DuPont Fayetteville Works
2004 —2006
Sample ID
Monitoring
APFO
(Groundwater Monitoring Well Description)
Date
(µg/L)
MW-IS
02/03/04
NQ (<0.050)
Onsite monitoring well located near the inactive Biosludge
Lagoon area in the perched groundwater above a local clay
06/20/05
NQ (<0.050)
01/24/06
0.038
feature; South of the APFO Manufacturing Facility.
MW-2S
Onsite monitoring well located near the inactive Biosludge
Lagoon area in the perched groundwater above a local clay
06/20/OS
NQ (<0.050)
feature; South of the APFO Manufacturing Facility.
MW-5D
Onsite monitoring well located near the inactive Biosludge
Lagoon area in the surficial groundwater beneath a local clay
06/20/OS
NQ (<0.050)
feature; South of the APFO Manufacturing Facility.
MW-7S
Onsite monitoring well located near the inactive Biosludge
Lagoon area in the perched groundwater above a local clay
10/18/OS
0.047
feature; South of the APFO Manufacturing Facility.
MW-lOD
Onsite monitoring well located near the inactive Biosludge
Lagoon area in the surficial groundwater beneath a local clay
06/20/OS
ND (<0.100)
feature; South of the APFO Manufacturing Facility.
NAF-01
02/04/04
0.062
Onsite monitoring well located upgradient of the Nafion®
06/15/05
0.104
Common Sump in the perched groundwater above a local clay
feature; Southeast of the APFO Manufacturing Facility.
10/13/05
0.151
02/01/06
0.115
NAF-02
02/04/04
0.307
Onsite monitoring well located downgradient of the Nafion®
06/15/05
0.338
Common Sump in the perched groundwater above a local clay
feature; Southeast of the APFO Manufacturing Facility.
10/14/05
0.246
02/01/06
0.316
NAF-03
02/04/04
1.530
Onsite monitoring well located downgradient of the Nafion®
06/15/05
0.663
Common Sump in the perched groundwater above a local clay
feature; Southeast of the APFO Manufacturing Facility.
10/14/05
0.872
01/25/06
0.434
µg/L = micrograms per liter or parts per billion
Contains Confidential Business Information
DEQ-CFW 00076597

Biennial Report for APFO Manufacture Page 4 of 11
Calendar Years of 2004 and 2005 July 25, 2006
DuPont Company — Fayetteville Works
Summary of Groundwater Analytical Results
DuPont Fayetteville Works
2004 — 2006
Sample ID
Monitoring
APFO
(Groundwater Monitoring Well Description)
Date
(µg/L)
NAF-04
02/04/04
0.124
Onsite monitoring well located downgradient of the Nafion®
06/17/05
0.093
Common Sump in the perched groundwater above a local clay
feature; Southeast of the APFO Manufacturing Facility.
10/18/05
0.212
02/01/06
0.065
NAF-05A
Onsite monitoring well located downgradient of the Nafion®
11/11/04
0.239
10/13/05
0.187
Common Sump in the perched groundwater above a local clay
feature; Southeast of the APFO Manufacturing Facility.
NAF-05B
Onsite monitoring well located downgradient of the Nafion®
Common Sump in the surficial groundwater beneath a local
11/11/04
ND (<0.010)
clay feature; Southeast of the APFO Manufacturing Facility.
NAF-06
Onsite monitoring well located northeast of the
06/16/05
0.262
Fluoromonomers production area in the perched groundwater
10/14/05
0.535
above a local clay feature; Southeast of the APFO
Manufacturing Facility.
01/31/06
0.303
NAF-07
Onsite monitoring well located northeast of the
06/16/05
NQ (<0.050)
Fluoromonomers production area in the perched groundwater
10/14/05
0.085
above a local clay feature; Southeast of the APFO
Manufacturing Facility.
01/31/06
0.065
NAF-08A
Onsite monitoring well located southeast of the
06/17/05
0.072
Fluoromonomers production area in the perched groundwater
10/13/05
0.172
above a local clay feature; Southeast of the APFO
Manufacturing Facility
01/31/06
0.053
NAF-08B
Onsite monitoring well located southeast of the
06/21/05
ND (<0.010)
Fluoromonomers production area in the surficial groundwater
10/13/05
NQ (<0.011)
beneath a local clay feature; Southeast of the APFO
Manufacturing Facility
01/31/06
NQ (<0.012)
NAF-09
06/16/05
0.080
Onsite monitoring well located south of the Fluoromonomers
production area in the perched groundwater above a local clay
10/13/05
0.121
02/01/06
0.086
feature; Southeast of the APFO Manufacturing Facility.
µg/L = micrograms per liter or parts per billion
Contains Confidential Business Information
DEQ-CFW 00076598

• Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 5 of 11
July 25, 2006
Summary of Groundwater Analytical Results
DuPont Fayetteville Works
2004 — 2006
Sample ID
Monitoring
APFO
(Groundwater Monitoring Well Description)
Date
(µg/L)
NAF-10
06/16/05
0.122
Onsite monitoring well located south of the Fluoromonomers
production area in the perched groundwater above a local clay
10/13/05
0.134
02/01/06
0.088
feature; Southeast of the APFO Manufacturing Facility.
NAF-11A
Onsite monitoring well located northeast of the
07/05/05
NQ (<0.05)
Fluoromonomers production area in the perched groundwater
10/17/05
0.021
above a local clay feature; Southeast of the APFO
Manufacturing Facility.
01/26/06
0.048
NAF-11B
Onsite monitoring well located northeast of the
07/05/05
ND (<0.010)
Fluoromonomers production area in the surfcial groundwater
beneath a local clay feature; Southeast of the APFO
Manufacturing Facility.
10/17/05
ND (<0.002)
4328MLR
11/16/05
0.011
Offsite private residential drinking water well; Northeast of
the APFO Manufacturing Facility.
11/16/05
NQ (<0.022)
6999PED
11/16/05
ND (<0.005)
Offsite private residential drinking water well; Northwest of
the APFO Manufacturing Facility.
11/16/05
ND (<0.002)
PW-01
Offsite private residential drinking water well; West of the
01/25/06
ND (<0.002)
APFO Manufacturing Facility.
PW-02
Offsite transient noncommunity public water system; West of
01/25/06
ND (<0.002)
the APFO Manufacturing Facility.
PW-03
Offsite transient noncommunity public water system;
01/25/06
ND (<0.002)
Southeast of the APFO Manufacturing Facility.
PW-04
Onsite transient noncommunity public water system;
01/25/06
ND (<0.002)
Northwest of the APFO Manufacturing Facility.
PW-05
Offsite transient noncommunity public water system; North-
01/25/06
NQ (<0.012)
northwest of the APFO Manufacturing Facility.
µg/L = micrograms per liter or parts per billion
Contains Confidential Business Information
DEQ-CFW 00076599

Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 6 of 11
July 25, 2006
Summary of Groundwater Analytical Results
DuPont Fayetteville Works
2004 — 2006
Sample ID
Monitoring
APFO
(Groundwater Monitoring Well Description)
Date
(µg/L)
PW-06
Offsite transient noncommunity public water system; North-
01/25/06
ND (<0.002)
northwest of the APFO Manufacturing Facility.
PW-07
Offsite private residential drinking water well; South-
03/30/06
ND (<0.001)
southwest of the APFO Manufacturing Facility.
PZ-04
Onsite monitoring well located southeast of Nafion® Common
Sump in the perched groundwater above a local clay feature;
02/01/06
0.617
Southeast of the APFO Manufacturing Facility.
PZ-12
10/17/05
0.021
Onsite monitoring well located southeast of the APFO
Manufacturing Facility in the perched groundwater above a
12/13/05
0.015
01/26/06
0.018
local clay feature.
PZ-15
Onsite monitoring well located northwest of the PMDF
Facility in the perched groundwater above a local clay feature;
O1/26/06
0.032
South-southeast of the APFO Manufacturing Facility.
PZ-16
Onsite monitoring well located southeast of the PMDF Facility
in the perched groundwater above a local clay feature; South-
southeast of the APFO Manufacturing Facility.
SMW-01
02/03/04
ND (<0.010)
Onsite monitoring well located east of the Construction Gate
entrance near Highway 87 in the surficial aquifer; Southwest
06/20/05
ND (<0.010)
01/24/06
ND (<0.002)
of the APFO Manufacturing Facility.
SMW-02
02/03/04
ND (<0.010)
Onsite monitoring well located north of the River Pump Road,
06/20/05
ND (<0.010)
north of the Fluoromonomers manufacturing area, in the
09/06/05
NQ (<0.007)
perched groundwater above a local clay feature; East of the
10/17/05
ND (<0.002)
APFO Manufacturing Facility.
01/26/06
NQ
µg/L = micrograms per liter or parts per billion
Contains Confidential Business Information
DEQ-CFW 00076600

Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 7 of 11
July 25, 2006
Summary of Groundwater Analytical Results
DuPont Fayetteville Works
2004 — 2006
Sample ID
Monitoring
APFO
(Groundwater Monitoring Well Description)
Date
(µg/L)
SMW-02B
Onsite monitoring well located north of the River Pump Road,
north of the Fluoromonomers manufacturing area, in the
10/17/05
ND (<0.022)
surficial groundwater beneath a local clay feature; East of the
APFO Manufacturing Facility.
SMW-04B
10/17/05
2.25
Onsite monitoring well located north of the River Pump Road,
11/10/05
2.51
north of the APFO Manufacturing Facility, in the surficial
01/24/06
1.30
groundwater beneath a local clay feature.
SMW-05
10/17/05
147
Onsite monitoring well located north of and adjacent to the
APFO Manufacturing Facility, in the perched groundwater
above a local clay feature.
12/13/05
765
SMW-05P
Onsite monitoring well located north of and adjacent to the
02/22/06
6.5
APFO Manufacturing Facility, in the surficial groundwater
beneath a local clay feature.
SMW-06
Onsite monitoring well located east of and adjacent to the
12/13/05
0.224
APFO Manufacturing Facility, in the perched groundwater
above a local clay feature.
01/26/06
0.261
SMW-07
10/17/05
0.019
Onsite monitoring well located south of and adjacent to the
12/13/05
NQ (<0.012)
APFO Manufacturing Facility, in the perched groundwater
above a local clay feature.
01/26/06
NQ (<0.012)
#562877 - Domestic H2O
Inactive onsite drinking water well located near the
Powerhouse area, screened in the Upper Cape Fear confined
07/15/04
ND (<0.010)
aquifer; South of the APFO Manufacturing Facility.
#562878 — Domestic H2O
Inactive onsite drinking water well located near the
Powerhouse area, screened in the Upper Cape Fear confined
07/15/04
ND (<0.010)
aquifer; South of the APFO Manufacturing Facility.
INSITU #1 Shallow
Onsite monitoring well located near the facility's northern
property line in the upper level of the surficial groundwater;
12/20/OS
NQ (<0.013)
North-northeast of the APFO Manufacturing Facility.
µg/L = micrograms per liter or parts per billion
Contains Confidential Business Information
DEQ-CFW 00076601

Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 8 of 11
July 25, 2006
Summary of Groundwater Analytical Results
DuPont Fayetteville Works
2004 - 2006
Sample ID
Monitoring
APFO
(Groundwater Monitoring Well Description)
Date
(µg/L)
INSITU #2 Deep
Onsite monitoring well located near the facility's northern
property line in the lower level of the surficial groundwater;
12/20/OS
ND (<0.027)
Northwest of the APFO Manufacturing Facility.
INSITU #2 Shallow
Onsite monitoring well located near the facility's northern
property line in the lower level of the surficial groundwater;
12/20/OS
NQ (<0.013)
Northwest of the APFO Manufacturing Facility.
LTW-01
Onsite monitoring well located near the facility's eastern
property line along the Cape Fear River in the surficial
02/02/06
0.033
groundwater; East of the APFO Manufacturing Facility.
LTW-02
Onsite monitoring well located near the facility's eastern
property line along the Cape Fear River in the surficial
02/02/06
ND (<0.002)
groundwater; East-southeast of the APFO Manufacturing
Facility.
LTW-03
Onsite monitoring well located near the facility's eastern
property line along the Cape Fear River in the surficial
02/01/06
ND (<0.002)
groundwater; East-southeast of the APFO Manufacturing
Facility.
LTW-04
Onsite monitoring well located near the facility's eastern
property line along the Cape Fear River in the surficial
O1/24/06
ND (<0.002)
groundwater; Southeast of the APFO Manufacturing Facility.
LTW-05
Onsite monitoring well located near the facility's eastern
02/02/06
ND (<0.002)
property line along the Cape Fear River in the surficial
groundwater; Southeast of the APFO Manufacturing Facility.
µg/L = micrograms per liter or parts per billion
4. Summary report of surface water monitoring results
The Fayetteville Works facility annually monitors for APFO in the site's surface water
discharge to the Cape Fear River. This monitoring location is the site's final effluent
Contains Confidential Business Infor►nation
DEQ-CFW 00076602

Biennial Report for APFO Manufacture Page 9 of 11
Calendar Years of 2004 and 2005 July 25, 2006
DuPont Company — Fayetteville Works
discharge at the NPDES permitted Outfall 002. The results of that monitoring are shown in
the following table:
Surface Water Sample ID
Monitoring
APFO
(Sample Description)
Date
(µg/L)
Outfall002
02/03/04
NQ (<0.050)
Final NPDES permitted wastewater discharge; Located
south of the central wastewater treatment plant and south of
06/20/OS
NQ (<0.050)
01/24/06
0.025
the APFO Manufacturing Facility.
µg/L = micrograms per liter or parts per billion
Monitoring of stagnant water in a stormwater conveyance ditch was conducted in 2005.
While this stagnant water meets the definition of a surface water, it should be noted that this
water consisted of exclusively non -flowing puddles of water at the time of the sampling.
The results of that monitoring are shown in the following table:
Surface Water Sample ID
(Sample Description)
Monitoring
Date
APFO
(µg/L)
SW-01
Stormwater ditch north of Fluoromonomers area; East of the
APFO Manufacturing Facility.
06/20/2005
0.100
09/06/2005
0.129
10/07/2005
0.068
SW-02
Stormwater ditch north of Fluoromonomers area; East of the
APFO Manufacturing Facility.
06/20/2005
0.135
09/06/2005
0.302
10/07/2005
0.157
SW-03
Stormwater ditch north of Fluoromonomers area; East of the
APFO Manufacturing Facility.
06/21/2005
0.142
09/06/2005
0.298
10/07/2005
0.149
SW-04
Stormwater ditch north of Fluoromonomers area; East of the
APFO ManufacturingFacility.10/07/2005
06/20/2005
0.093
0.147
SW-05
Stormwater ditch north of Fluoromonomers area; East of the
APFO Manufacturing Facility.
10/07/2005
0.139
µg/L = micrograms per liter or parts per billion
Sampling of two unnamed tributaries to the Cape Fear River, and two streams flowing to
one of those tributaries, was conducted in 2006. It is believed that the base flow in these
tributaries is primarily from expressed groundwater, with additional episodic flow from
stormwater runoff. The surface water samples described in the table that follows were taken
Contains Confidential Business Information
DEQ-CFW 00076603

Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 10 of 11
July 25, 2006
during base flow conditions. The results of that monitoring are shown in the following
table:
Surface Water Sample ID
Monitoring
APFO
(Sample Description)
Date
(µg/L)
SW-06
Located east of the Fluoromonomers area, in an unnamed
01/25/2006
0.027
tributary (#1) to the Cape Fear River
SW-07
Located east of the Fluoromonomers area, in a stream (#1)
01/25/2006
0.040
flowing into the unnamed tributary #1
SW-08
Located east of the Fluoromonomers area, in a stream (#2)
01/25/2006
0.032
flowing into the unnamed tributary #1
SW-09
Located east of the PMDF manufacturing area, in an
01/25/2006
0.027
unnamed tributary (#2) to the Cape Fear River
µg/L = micrograms per liter or parts per billion
In 2005, the site's non -contact cooling water and the influent and effluent of the river water
sediment basin were sampled. Both of these waters ultimately discharge through the site's
NPDES permitted Outfall 002. The non -contact cooling water is raw river water that is
pumped from the Cape Fear River, through equipment to remove heat, and then back to the
river. The river water sediment basins receive river water and its sediment that has been
removed from the river water as a result of clarification. The results of that monitoring are
shown in the following table:
Surface Water Sample ID
Monitoring
APFO
(Sample Description)
Date
(µg/L)
NR-01
Non -contact, once -through cooling water flowing in the
09/06/2005
0.077
open ditch south of the Fluoromonomers area; East of the
APFO Manufacturing Facility
RW-01
Influent to the filtered river water sediment basin located
09/06/2005
0.083
west of the Fluoromonomers area; East of the APFO
Manufacturing Facility
RW-02
Effluent from the filtered river water sediment basin located
09/06/2005
0.081
west of the Fluoromonomers area; East of APFO the
Manufacturing Facility
µg/L = micrograms per liter or parts per billion
Contains Confidential Business Information
DEQ-CFW 00076604

Biennial Report for APFO Manufacture
Calendar Years of 2004 and 2005
DuPont Company — Fayetteville Works
Page 11 of 11
July 25, 2006
5.
6.
Workplace industrial hygiene monitoring
The DuPont Company — Fayetteville Works began workplace monitoring for
perfluorooctanoic acid (PFOA) with the start up of the APFO Manufacturing Facility in
2002. The workplace monitoring in 2004 and 2005 consisted of stationary area monitors
that sampled the building air space for twelve (12) continuous hours. These sampled
locations are limited access restricted areas in which personnel wear both respiratory and
dermal personnel protection. The 12-hour time weighted average (TWA) PFOA
concentration values are shown in the following table:
Number
PFOA
PFOA
PFOA
Year
Sample Type
of
Minimum
Maximum
Average
Samples
Conc.
Conc.
Conc3
(mg/m)
(mg/m)
(mg/m )
2004
Area 12-hour
TWA
85
0.00021
1.9
0.041
2005
42
<0.00021
0.061
0.0081
mg/m3 = milligrams per cubic meter
Summary data on employee blood monitoring results
At the DuPont Company — Fayetteville Works, blood serum levels of PFOA have been
measured since 2002. A summary of results of employees with identified APFO exposure
potential in 2004 and 2005 is shown in the following table:
PFOA
PFOA
PFOA
Number of
Minimum
Maximum
Average
Year
Samples
Concentration
Concentration
Concentration
(ppm)
(ppm)
(ppm)
2004
56
0.0027
1.87
0.437
2005
64
0.0031
4.54
0.504
ppm = parts per million
Additional monitoring information
Additional APFO monitoring information that is not specified by the LOI is being reported in
Appendix A of the site's Phase II RCRA Facility Investigation (RFI) Report. This additional
information will be the analytical results for APFO concentrations of samples taken of soil,
sediment, ambient air, and the Cape Fear River. A copy of the Phase II RFI Report was
submitted to the N.C. Division of Waste Management on June 30, 2006 and will be provided to
EPA Docket OPPT-2003-0012 as a separate submission.
Contains Confidential Business Information
DEQ-CFW 00076605

I
t
OUp�NT DuPont Fluoroproducts
® 22828 NC Highway 87 W
Fayetteville, NC 28306-7332
CERTIFIED MAIL — RETURN RECEIPT REQUESTED
June 28, 2006
Mr. Alan W. Klimek, P.E.
Director
NCDENR — Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJECT: Revised Cape Fear River APFO Sampling Results
Dear Mr. Klimek:
On April 3, 2006, the DuPont Company — Fayetteville Works reported to the Division of
Water Quality the results of sampling in the Cape Fear River basin for the compound ammonium
perfluorooctanoate (APFO or C8). DuPont subsequently learned that an unvalidated analytical
method was used to generate those results. The retained river water samples were then analyzed
with the correct validated method, and those results are given on the attached table.
You will see that the attached results are similar to what was reported to you in April.
If you have any questions regarding this information, or if you need more details, please feel
free to call me at [phone].
Environmental Manager
Attachment
cc: Ms. Belinda Henson — NCDENR Division of Water Quality — Fayetteville
Ms. Jessica Miles — NCDENR Division of Environmental Health — Raleigh
Ms. Debra Benoy — NCDENR Division of Environmental Health — Wilmington
Mr. Larry Stanley — NCDENR Division of Waste Management — Raleigh
Ms. Mary Dominiak — EPA — Washington DC (via [e-mail])
E.I. du Pont de Nemours and Company
DEQ-CFW 00076606

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Cape Fear River r
AM 2
Monitoring _
Locations AdLocations
""T� 0.127 ppb
Legend 0.104 ppb L
Middle Cape Fear Monitoring Sites
b.: NCOWQ Benthic Monitoring Sites 0.007 ppb
NCOWQ Ambient Monitoring Sites
County Boundaries 0.095 ppb
Ma)or Highways
Municipal Boundaries 0.105 ppb
Surface Waters (USGS 1: 100,000 scale data)
5 0 5 10 15 20 25 Miles
CFR at Erwin
CFR at I-95
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Ad8 C
.. _ Af! C-i
c Rockfish Creek
CFR at DuPont
S All6
I �� c - CFR near Tarheel
Ai 28 \ I ("0 ;

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CAPE FEAR RIVER MONITORING FOR AMMONIUM PERFLUOROOCTANOATE (APFO or C-8)
[ Revised Analytical Results ]
Sample
Sample
Sample Location
MCFRBA
NCDENR
APFO
Date
ID No.
Description
p
Location
DWQ Storet
(µg/L)
ID No.
Number
Cape Fear River at NC
02/15/06
CFR-5-El
Highway 217 (Bridge in
M 5
B6840000
0.127
Erwin, NC)
02/16/06
CFR-10-El
Cape Fear River at the
M 10
B7500000
0.104
I-95 bridge
02/16/06
CFR-14-El
Cape Fear River at
M 14
B8290000
0.095
DuPont river water intake
Cape Fear River upstream
02/14/06
CFR-16-El
of Smithfield Packing
M 16
B8302000
0.105
(North of Tarheel, NC)
02/16/06
CFR-13_El Note
Rockfish Creek at
M 13
B8230000
0.007
NC Highway 87
02/16/06
CFR-13-E1-2 Note
Rockfish Creek at
M 13
B8230000
<0.006
NC Highway 87
Note: A field duplicate sample was taken at the Rockfish Creek location
MCFRBA = Middle Cape Fear River Basin Association
µg/L = micrograms per liter (parts per billion)
Limit of Quantification (LOQ) for the procedure was 0.006 µg/L

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DEQ-CFW 00076609

Clean
Water
for
North Carolina
2009 Chapel Hill Rd. Durham, NC 27707
Teresa Rodriguez
NC Div. of Water Quality - NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
January 25, 2007
Comments on Draft NPDES Permit NC0003573 for DuPont -Fayetteville Works, Bladen County
Dear Ms. Rodriguez:
On behalf of Clean Water for North Carolina, we wish to submit the following comments on the
draft renewal permit for DuPont -Fayetteville Works.
The DuPont facility is not only the site of six manufacturing processes, including the newly -
added polyvinyl flouride process, but it is also a neighbor to the Fayetteville community and all other
downstream and downwind communities. We believe that it is vital for the protection of these residents'
drinking water supplies that the testing requirements in this permit are strengthened to not only test
existing parameters more frequently but also to add parameters that are either new, have been
previously overlooked, or which have been removed as a result of demonstration of compliance several
years ago.
The detail and straightforwardness of the fact sheet have been very helpful to us in reviewing
the permit and understanding the DuPont facility. However, there are several inconsistencies
throughout the draft permit regarding testing frequency. All parameters with daily maximum limits
should be sampled and analyzed daily to ensure that the maximum is not exceeded. Total suspended
solids and BOD, for example, are being discharged from Outfall 001 and, though they have daily
maxima, they are not tested for on a daily basis.
Another critical example of this is the testing for hexachlorobenzene, which is currently done
only annually. This toxin is a likely human carcinogen and once released, it lingers in the environment
and accumulates in plants, animals, and soil. Hexachlorobenzene should be tested for daily, to ensure
the safety of Cape Fear River Basin residents. Furthermore, the permits language regarding the
testing of hexachlorobenzene ('sufficiently sensitive") must be more explicit in its requirements for
analytical methodology. We are aware that such non-specific language has allowed some facilities to
use analytical methods that are not capable of detecting down to NC water quality standards. Wherever
possible, analytical methods should be prescribed to ensure their appropriateness.
All listed parameters should have monthly averages as well as daily maxima to ensure that
safe levels are not being exceeded. From Outfall 002, BOD, COD, dissolved oxygen, total
phosphorous, and total nitrogen should have stated limits.
A major fault in the draft permit is that carries over a waiver regarding testing requirements
from the previous permit. Any monitoring previously waived should not be automatically carried
through to the next permit, as the current permit states that the waiver is "good only for the term of the
permit." Permittees should have to prove compliance at least as often as every permit renewal to have
DEQ-CFW 00076610

requirements waived. Preferably, compliance should be proven annually, or within 30 days after the
introduction of any new processes at the facility. The substances listed in A (2) Subpart I, for example,
include many hazardous toxins, which if in use, or potentially in stormwater discharges, should be
tested for regularly to ensure public safety. This is especially critical given the addition of the PVF
process at the Fayetteville Works.
The daily maximum fluoride discharge from Outfall 002 is extremely alarming. Excess fluoride
in drinking water can have serious health impacts for humans, as it accumulates in bones, damages
teeth, and is a suspected neurotoxin. Studies have shown that both aquatic and terrestrial ecosystems
can be severely damaged by fluoride toxicity as well. The maximum must be lowered significantly to
safeguard both downstream residents' drinking water and the health of the Cape Fear River and
fluoride discharge levels must be limited and tested on a daily basis.
The downstream "mixing zone" of 4500 feet should be removed, and instream testing should
be done immediately below the discharge point to prevent the River from diluting wastewater and
allowing degradation of the River within that than permitted. If there are financial constraints on the
mixing zone being removed, the statutory requirement for a "variance," which this effectively
constitutes, requires that these be completely documented and available to the public. A compliance
point must not be placed nearly a mile downstream of the facility simply for the convenience of a
monitoring entity.
Wastewater must be tested for vinyl fluoride at the most upstream compliance discharge point,
and at final Outfall 02, as the facility is adding the PVF process. This is especially critical since DuPont
acknowledges that some amount of unreacted vinyl fluoride will be discharged. Vinyl fluoride is a
suspected human carcinogen and has been shown to cause numerous types of cancers in mice and
rats, in much the same way as vinyl chloride and vinyl bromide.
Though all PFOA wastes are reported to be transported off -site for disposal, the permit should
include monitoring requirements and limitations for PFOA and related compounds, as PFOA has been
linked to cancer and birth defects in animals and is being increasing regulated in groundwater and
drinking water standards and action levels. Even small discharges of a substance as toxic as PFOA
into the Cape Fear River can impact downstream drinking water, so limiting and testing for PFOA in
wastewater discharges is an important step in protecting the area's water supply sources.
The required off -site disposal of waste from the PFOA plant should be included in the permit,
as should the identity of the off -site facility. The permit should also require proof, such as a signed
affidavit of receipt from an appropriate facility, that all waste from the PFOA process is taken off site for
hazardous waste disposal. Additionally, any water intake for the PFOA process should be included in
the water balance sheet regardless of off -site waste treatment
DWQ's interim groundwater standard of 2.0 ppb for PFOA is almost certainly not sufficiently
protective of human health. It relieves DuPont of all but very limited monitoring and clean-up
responsibilities at the Fayetteville works (only immediately around the PFOA plant) and potentially
endangers North Carolina residents' well water. The setting of this standard by DWQ prematurely,
before conclusion of review by the NC Science Advisory Board, and using safety factor calculations
regarding which an EPA official recently described PFOA as a "poster child" for their inappropriateness,
is a dangerous precedent, While NC regulations require the Director to initiate permanent rulemaking
for a standard within 3 months, once an interim standard is set, DWQ knows there will be considerable
resistance from the regulated entity to setting a standard that is more protective, making this "interim"
limit highly problematic. Most states are looking at far more protective groundwater standards or action
levels of 0.5 ppb or less. DuPont -Fayetteville Works is the only manufacturer of PFOA in the country;
therefore North Carolina should take a leading role in regulating this toxin and protecting the state's
residents.
The ongoing violation of NC's instream turbidity standard and accumulation of sediments
carried by the wastewater and stormwater flows through the eroding long ditch to the Cape Fear River,
have been facilitated by this distant downstream monitoring point. Aerial photographs showing the flow
of sediments into the River from this ditch and buildup of sediment have been presented at a 2005
meeting where DWQ Director Alan Klimek and other staff were present This is a situation which has
been developing for years, a clear Clean Water Act violation and we have seen no enforcement action
DEQ-CFW 00076611

on the part of the Division. Turbidity, which was listed on the fact sheet but absent from the permit
monitoring requirements, must be included and measured daily at a specified point immediately
downstream of the discharge point, given the acknowledged problems being caused by the erosion of
the ditch.
Upon reviewing the permit application materials, We found several additional issues to be
addressed. The most pressing of these is sample retention. An aliquot of all testing samples should be
retained in case the need for retesting arises. The DWQ should not accept any "data remediation" by
the Permittee in response to abnormal test results. For example, the abnormal phosphorous test
results that occurred in March and December of 2005 were simply adjusted to appear within a normal
range. There is an obvious conflict of interest for the Permittee in these instances, and sample
retention allows for cases like these to be soundly resolved with retesting. Furthermore, while we
understand the Division's routine reliance on self -reported discharge monitoring data, personnel from
the Division of Water Quality should cant' out at least one annual split sampling on an unannounced
visit to assure reliable analysis of all water quality parameters.
We also have some concerns about the public notification process. The permittee's name
should be prominently shown at the beginning of all public notices; in DuPont's case it was not
mentioned until the final paragraph. Legal notices are a largely ineffective way to ensure that the public
is aware of coming permit public comment periods, but given the requirements of NC statute, all efforts
must be made to increase the likelihood that the public will actually see them. Most residents, who have
the right to be informed, will simply not read the entire notice without knowing what it actually refers to.
Public notices will be much more informative when the permittee's name is in the heading.
Finally, we noticed in the permit application materials that Mr. Michael Johnson corrected a
possible error regarding testing frequency that would have resulted in less frequent testing. We concur
with the need for this correction and appreciate his vigilance in this matter.
Because of the numerous concerns regarding this permit and significant public interest we
have found in contacts with residents near and downriver from this facility, we are requesting that a
public hearing be held. Please notify us (see below) as to when the hearing is scheduled.
Thank you for the opportunity to comment on this draft permit.
Sincerely, , 'f
Jill eman and Hope Taylor -Guevara
Clean Water for North Carolina
Phone: [phone]
E-mails: 0125(d-)duke.edu and [e-mail]
DEQ-CFW 00076612

Comments on DuPont Fayetteville NPDES Permit
Subject: Comments on DuPont Fayetteville NPDES Permit
From: "Steven Skavroneck" <[e-mail]>
Date: Tue, 23 Jan 2007 15:40:19 -0500
To: <[e-mail]>
I am forwarding the attached comment letter on the proposed reissuance of the NPDES permit for the DuPont
Fayetteville Works on behalf of the Cape Fear River Watch Inc.
Steven Skavroneck
Board Member
Cape Fear River Watch Inc.
DuPont Permit 012307.doc', Content -Type: application/msword
Content -Encoding: base64
of 1 1/29/2007 2:51 PM
DEQ-CFW 00076613

i
'PI G-
`FR
617 Surry Street
Wilmington, NC 28401
[phone]
1-800-380-3485
[e-mail]
www.cfrw.us
OFFICERS
Paul Nelson, President
Chuck Crawford, Vice President
Audrey Albrecht, Secretary
Dave Pyle, Treasurer
BOARD OF DIRECTORS
->W^
w,47%ex"R&e A144 &1Cfi
MOADER
Printed on Recycled Paper
January 23, 2007
Environmental Management Commission/ NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Draft Permit NC0003573
To Whom it May Concern:
Richard Cecelski
Thank you for the opportunity for Cape Fear River Watch Inc. to
Fred crouch
comment on this draft permit. Cape Fear River Watch has been a
proponent of water quality in southeastern North Carolina since 1993.
Joe Gaughan
Our mission is to protect and improve the water quality of the Lower
Tom Haney
Cape Fear River Basin through education, advocacy, and action. We
Jane Hartley
have the following comments relating to the draft NPDES permit for the
DuPont Fayetteville Works wastewater treatment plant.
Sharon Hatton
Sue Hayes
The permit should require monitoring and compliance with effluent
Rob Moul
limits for PFOA (C8). The company has indicated that all the discharge
from the PFOA plant is treated off site. This should either be made a
Paula May Murray
requirement of the renewed permit or else effluent limits promulgated
Jeff Newman
for PFOA. There is nothing in the proposed permit to prevent DuPont
Jennifer O'Keefe
from treating the PFOA discharge on site and if this is done there would
be no requirement for them to monitor for PFOA in the discharge.
Brad Rosov
Steve Skavroneck
In addition, the interim groundwater standard of 2.0 parts per billion for
Dave Thomas
PFOA is too lax. This standard relieves DuPont of nearly all clean up
responsibilities for the discharge that has been previously reported.
Mark westenaorff
North Carolina state health officials have stated that the standard for
STAFF
PFOA should be zero until the health risks are fully understood.
Dick Ehrhart
Elsewhere, the standard has been set at 0.5 ppb. This would serve as a
Business Manager
more appropriate interim standard.
Joe Abbate
Greenfield lake Director
The downstream mixing zone of 4,500 feet should be removed. Instead,
monitoring should be required at the point where the DuPont discharge
enters the Cape Fear River.
The daily maximum limitation for fluoride (7,917 pounds per day)
seems extremely high. This is a concern because fluoride accumulates in
DEQ-CFW 00076614

animal bones, in plants and in the soil. If this limit remains in the final permit, the permit should also
require monitoring of fluoride accumulation in river sediment and additional bioaccumulation studies on
lower trophic catfish since they concentrate fluorides and some metals in their tissues.
For hexachlorobenzene, the phrase "sufficiently sensitive" relating to testing method is too ambiguous.
The required method sensitivity should be more discretely defined.
In addition, we request a public hearing on this permit, and that we be notified about the date, time and
place of the hearing when it is scheduled. Thank you for your consideration of these comments.
Sincerely,
Paul Nelson
President
DEQ-CFW 00076615

DEQ-CFW 00076616

DEQ-CFW 00076617