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Home My WebLink About201706201058Mr. William Murray 604 The Cape Boulevard Wilmington, NC 28412 Dear Mr. Murray: Michael F. Easley Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources June 5, 2007 Subject: Coleen H. Sullins, Director Division of Water Quality NPDES Permit NC0003573 DuPont Fayetteville Works The Division received your letter offering comments on the draft NPDES permit for DuPont Fayetteville Works. All the letters received during the permit comment period presented many common concerns with the draft permit. With this response the Division would like to address the major issues raised and explain the basis for the permit conditions that were subject to comments. We have considered all comments offered by individuals in developing the final permit and modified the permit accordingly. The Division offers the following responses (public comments are highlighted in bold): 1. Parameters with daily limits should be sampled daily (BOD and COD at outfall 001) — Measurement. frequencies for industrial NPDES permits are defined in 15A NCAC 2B .0508 according to industrial SIC codes and facility classification. The draft permit for DuPont is consistent with this regulation. The wastewater treatment plant is classified as a Grade III facility, and as such, sampling frequencies for BOD and COD are established as three times per week. For toxicants that present reasonable potential to exceed water quality standards, Division guidelines establish weekly monitoring. In the case of parameters not listed in the regulation, specific monitoring frequencies will be defined by individual permit conditions. 2. Hexachlorobenzene should be tested daily, the permit language should be more specific regarding testing — The testing frequency for this parameter was determined based on an evaluation of reasonable potential. Reported data shows no detections of hexachlorobenzene. The requirement to use a sufficiently sensitive test is intended to require the facility to use the more sensitive method that is available that can detect to levels below the permit limit. Sometimes approved methods do not detect at levels below the permit limit. In those cases the most sensitive method must be used until a new method is approved that can detect lower levels, which then becomes the most sensitive analytical method. 3. All parameters should have monthly average as well as daily maximum limits, BOD, COD, DO, total phosphorus and total nitrogen for outfall 002 — Outfall 002 is the combined outfall from the process and non -process wastewaters, which include stormwater and cooling waters. This outfall is not subject to effluent guidelines. Any limit developed for this outfall would be based on best professional judgement. The Division does not impose limits on all monitored parameters unless there is reason to believe the discharge would cause instream standards or criteria to be exceeded. 4. The permit carries over a waiver regarding testing requirements — The waiver was not carried forward from the previous permit. The permittee requested the waiver at permit renewal time. Data was submitted with the permit application to support the request for a waiver. After data review, the testing requirements for parameters listed in 40 CFR 414 Subpart I were waived in accordance to 40 CFR 122.44 for the period the permit is effective. 5. Lower the fluoride limit in Outfall 002 — The fluoride limit for outfall 002 is based on the fluoride water quality standard for freshwater of 1.8 mg/1 and the instream waste concentration for the discharge. In this case the discharge flow of 20.6 MGD gives an instream waste concentration is 3.7 %, resulting in an allowable concentration of 47 mg/1 or 8,195 lb/day. The limit of 7,917 lbs/day is more stringent as it was established from a previous waste load allocation under slightly different flow conditions. The more stringent limit always prevails in the permit. The Division considers this limit protective of water quality. 6. Remove the mixing zone of 4500 feet — The permit does not authorize a mixing zone. Compliance for all limited parameters is determined at the end of pipe. The location of the downstream sampling station is 4500 feet downstream from the discharge location, but this does not constitute a mixing zone. The instream monitoring locations are established by the Cape Fear River Monitoring Coalition and the Division to obtain representative data of the conditions of the river. 7. Add testing for vinyl chloride at outfall 001— Vinyl chloride has not been identified as a pollutant of concern. This parameter was not detected in outfalls 001 or 002 in testing required for the permit renewal application. 8. Add a limit for PFOA, include in the permit the outside disposal of PFOA, and require proof that all waste has been taken off-site. The interim groundwater standard for PFOA is not protective of human health — The Division will include monthly monitoring of PFOA at outfall 002 in the final permit. A limit can not be established at this time because there is no approved criteria or standard to develop a limit. When such criteria is developed the Division can then calculate an applicable limit. The Division and the Environmental Protection Agency are actively researching the effects of PFOA to determine safe levels. The NPDES program does not have authority to establish or modify a groundwater standard or to regulate the disposal of waste off- site. 9. DuPont has ongoing violations of the instream turbidity standard and sediments are accumulating on the river carried by the wastewater and stormwater that erodes the channel. Include daily monitoring for turbidity immediately downstream of the discharge point — DuPont is addressing the issue of erosion of the effluent channel. The Division is currently evaluating a proposal from DuPont to relocate the discharge and install an effluent diffuser. 10. The facility should retain an aliquot of all samples to re -test if the results are not normal. The Division should do at least one annual split sample analysis — It is up to the permittee to establish procedures such as obtaining additional aliquots when they sample the effluent. The Division does not routinely perform split samples. But the Division performs a separate sampling of the effluent at least once, often more, per permit cycle. 11. Request for a public hearing — In light of the above responses the Director of the Division has determined not to hold a public hearing on the subject permit. Thank you for your comments. If you have question, please contact Teresa Rodriguez at telephone number (919) 733-5083, extension 553. Sincerely, Gil Vinzani NPDES East Supervisor Cc: NPDES Files �.. O OFiW�—A•r.FR Mr. Michael E. Johnson Environmental Manager E.I. DuPont de Nemours &Company 22828 NC Hwy 87 W Fayetteville, North Carolina�28306-7332 Dear Mr. Johnson: Michael F. Easley Governor William G. Ross, Jr., Secretary North Cazolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality May 25, 2007 Subject: NPDES Permit Issuance Permit No. NC0003573 Fayetteville Works Bladen County Division personnel have reviewed and approved your application for renewal of the subject permit.. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended). The following modifications from your draft permit are included in the final permit: • Sampling frequency for conductivity was corrected to weekly. • The waiver for instream sampling that was inadvertently omitted in the draft permit is included in the footnotes for Outfall 002. • Monthly monitoring for PFOA was added to outfa11002 to gather effluent and instream data for this parameter. If any parts, measurement .frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may require- modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any .other Federal or Local governmental permit that maybe required. North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-5083 Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-0719 An Equal Opportunity/Affirmative Action Employer -50% Recycled/10%Post Consumer Paper NorthCazolina �aiura!!y Customer Service 1-877-623-6748 ', ,. Permit No. NC0003573 Fayetteville Works WWTP Page 2 , If you have any questions concerning this permit, please contact Teresa Rodriguez at telephone number (919) 733-5083, extension 553. Sincerely, ��i�w ,�yr •, Alan W. Klimek, P.E. Cc: NPDES.Files Fayetteville Regional Office -Surface Water Protection Aquatic Toxicology Unit EPA Region 4 Permit NC0003573 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY NA PERMIT TO DISCHARGE WASTEWATER UNDER THE 1TATION In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, E.I. DuPont de Nemours & Co. is hereby authorized to discharge wastewater and stormwater from a facility.located at DuPont -Fayetteville Works 22828 NC Highway 87 Duart Township Bladen County to receiving waters designated as the Cape Fear River in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof. The permit shall become effective July 1, 2007. This permit and the authorization to discharge shall expire at midnight on October 31, 2011 Signed this day May 25, 2007. Alan W. HIimek, P.E., Dir or Division of Water Quality By Authority of the Environmental Management Commission Permit NC0003573 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. E.I. DuPont de Nemours & Co., Inc. is hereby authorized to: 1. Continue to operate existing wastewater treatment facilities consisting of: • equalization; • neutralization; • aerated pre -digester tank; • nutrient feed system; • aeration tank; • dual clarifiers; • effluent flow measurement; • tertiary filters • DAF unit; • rotary filter for sludge thickening; • sludge filter press; and • steam heated sludge dryers. 2. Discharge treated process wastewater from Butacite, Nafion, Teflon® PMDF, and PVF, process stormwater, sanitary wastewater, and co -neutralized regenerate from said treated facilities through internal outfall 001; 3. Discharge stormwater, non -contact cooling water, boiler blowdown and condensate, and treated wastewater effluent from 001, through outfall 002 at the location specified on the attached map into the Cape Fear River, a class C water in the Cape Fear River Basin. Permit NC0003573 t A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting through the expiration date, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: Notes• 1. Chronic Toxicity (Ceriodaphnia) P/F ®3.3% February, May, August, November; see condition A: (4) of this permit. The compliance monitoring point for chronic toxicity shall be downstream of the confluence of outfall 001 and 002. THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS. 1=FFLUENT `LIMITATIONS MONITORING REQUIREMENTS PARAMETER L Monthly - Measurement Safnple�am le = Daily Maximum z, P ,, AveTa e - Fre= uen T e , _-kocation,. Flow (MGD) 2.0 Continuous Recording Effluent BODS, 200 C 191.3 lbs/day 508.2 lbs/day 3/Week Composite Effluent Total Suspended Solids 317.81bs/day 1030 lbs/day 3/Week Composite Effluent Temperature Weekly Grab Effluent Oil & Grease Monthly Grab Effluent Chronic Toxicity See Note 1 Quarterly Composite See Note I pH Between 6.0 and 9.0 Standard Units 3/Week Grab Effluent 40 CFR 414 Subpart I See Condition A. (2) Notes• 1. Chronic Toxicity (Ceriodaphnia) P/F ®3.3% February, May, August, November; see condition A: (4) of this permit. The compliance monitoring point for chronic toxicity shall be downstream of the confluence of outfall 001 and 002. THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS. Permit NC0003573 A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply with the limitations and monitoring frequencies established below at outfall 001: Acenaphthene Acrylonitrile Anthracene Benzene Benzo(a)anthracene 3,4-13enzofluoranthene Benzo(k)fluoranthene Benzo(a)pyrene Bis(2-ethylhexyl) phthalate Carbon Tetrachloride Chlorobenzene Chloroethane Chloroform Chrysene 0.174 0.465 See Note 2 Grab Effluent 0.174 0.465 See Note 2 Grab Effluent 0.757 1.909 See Note 2 Grab Effluent 0.174 0.465 See Note 2 Grab Effluent 0.292 1.073 See Note 2 Grab Effluent 0.174 0.465 See Note 2 Grab Effluent 0.181 0.481 See Note 2 Grab Effluent 0.174 0.465 See Note 2 Grab Effluent 0.181 0.481 See Note 2 Grab Effluent 0.813 2201 See Note 2 Grab Effluent 0.142 0.300 Sec. -Note 2 Grab Effluent 0.118 0.221 See Note 2 Grab Effluent 0.821 2.114 See Note 2 Grab Effluent 0.166 0.363 See Note 2 Grab Effluent 0.245 0.773 See Note 2 Grab Effluent 0.174 0.465 See Note 2 CTml' Rfflll . f - Di -n -butyl phthalate 0.213 0.450 See Note 2 Grab Effluent 1,2 -Dichlorobenzene 0.608 1.286 See Note 2 Grab Effluent ,3 -Dichlorobenzene 0.245 0.347 See Note 2 Grab Effluent 1,4 -Dichlorobenzene 0.118 0.221 See Note 2 Grab Effluent ,1-Dichloroethane 0.174 0.465 See Note 2 Grab Effluent 1,2-Dichloroethane 0.536 1.665 See Note 2 Grab Effluent 1,1-Dicbloroethylene 0.126 0.197 See Note 2 Grab Effluent ,2-trans-Dichloroethylene 0.166 10.426 See Note 2 Grab Effluent ,4-Dichlorophenol 0.308 0.884 See Note 2 Grab Effluent ,2-Dich1oropropane 1.207 1.815 See Note 2 Grab Effluent ,3-Dichloropropylene 0.229 0.347 See Note 2 Grab Effluent Diethyl phthalate 0.639 1.602 See Note 2 Grab Effluent 2,4 -Dimethylphenol 0.142 0.284 See Note 2 Grab Effluent Dimethyl phthalate 0.150 0.371 See Note 2 Grab Effluent ,6-Dinitro-o-cresol 0.615 2.185 See Note 2 Grab Effluent ,4-Dinitrophenol 0.560 0.970 See Note 2 Grab Effluent ,4-Dinitrotoluene 0.892 2.249 See Note 2 Grab Effluent ,6-Dinitrotoluene 2.012 5.057 See' Note 2' - Grab - Effluent Ethylbenzene 0252 .0352 See Note 2 Grab Effluent u Permit NC0003573 A. (2) SUBPART I REQUIREMENTS (CONTINUED) Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply with the limitations and monitoring frequencies established below at outfall 0012 Notes• 1. All units are lbs/day unless otherwise noted. 2. Monitoring for the specified parameters has been waived based on a demonstration made by the Permittee in accordance with 40 CFR 122.44(a)(2)(i). This waiver is good only for the term of the permit. Please note that any exceedence of the effluent limitations found herein shall be considered a permit violation subject to appropriate enforcement action. 3. The most sensitive analytical method available shall be employed for determining the presence of hexachlorobenzene in the effluent. =11 'EFFLUENT LIMITATIONS MONITORING-REQUIRI=ME PARAMETER Monthl Dail Y Y Meas a entSa le �lr m mp� Sampie. ; Avera e1-, ire' Maximums uen T e „_ .Location , Fluoranthene 0.197 0.536 See Note 2 Grab Effluent Fluorene 0.174 0.465 See Note 2 Grab Effluent Hexachlorobenzene 0.5 µg/L Annually3 Grab Effluent Hexachlorobutadiene 0.158 0.387 See Note 2 Grab Effluent Hexachloroethane 0.166 0.426 See Note 2 Grab Effluent Methyl Chloride 0.679 1.499 See Note 2 Grab Effluent Methylene Chloride 0.316 0.702 See Note 2 Grab Effluent Naphthalene 0.174 0.465 See Note 2 Grab Effluent Nitrobenzene 0.213 0.536 See Note 2 Grab Effluent -Nitrophenol 0.323 0.544 See Note 2 Grab Effluent -Nitrophenol 0.568 0.978 See Note 2 Grab Effluent Phenanthrene 0.174 0.465 See Note 2 Grab Effluent Phenol 0.118 0205 See Note 2 Grab Effluent Pyrene 0.197 0.529 See Note 2 Grab Effluent. Tetrachloroethylene 0.174 0.442 See Note 2 Grab Effluent Toluene 0205 0.631 See Note 2 Grab Effluent 2,4-Trichlorobenzene 0.536 1.105 See Note 2 Grab Effluent ,1,1 -Trichloroethane 0.166 0.426 See Note 2 Grab Effluent 1,1,2 -Trichloroethane 0.166 0.426 See Note 2 Grab Effluent Trichloroethylene 0.166 0.426 See Note 2 Grab Effluent Vinyl Chloride 0.821 2.114 See Note 2 Grab Effluent Notes• 1. All units are lbs/day unless otherwise noted. 2. Monitoring for the specified parameters has been waived based on a demonstration made by the Permittee in accordance with 40 CFR 122.44(a)(2)(i). This waiver is good only for the term of the permit. Please note that any exceedence of the effluent limitations found herein shall be considered a permit violation subject to appropriate enforcement action. 3. The most sensitive analytical method available shall be employed for determining the presence of hexachlorobenzene in the effluent. A. (3) Permit NC0003573 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting through the expiration date, the Permittee is authorized to discharge from Outfall 002 (boiler blowdown, once -through cooling water, and treated wastewater from outfall 001) Such discharges shall be limited and monitored by the Permittee as specified below: Notes. TI0NS EFFLUENT`LIMITi4It MONITORING; REQUIREMENTS PARAMETER it MontblIt Y Measurement Sample Sarraple_ r ` 1 Daily Maxmt�m Avera a Fre uen T T e , Locatio_ , Flow (MGD) Continuous Recording Effluent Effluent, Temperature, °C See Note 2 Dail y3 Grab Upstream, Downstream BODS, 20°C Quarterly Composite Effluent COD Quarterly Composite Effluent Effluent, Fludride4 79171bs/day Weekly Grab Upstream, Downstream Dissolved Oxygen Weekly Grab Upstream, Downstream PFOA5 Monthly Grab Effluent Total Phosphorus Monthly Composite Effluent Total Nitrogen (NOz+NOs+TKN) Monthly Composite Effluent Conductivity Weekly Grab Upstream, Downstream pH Between 6.0 and 9.0 Standard Units 3/Week Grab Effluent • 1. Upstream shall be at the Permittee's river pump station; downstream shall be at the boat ramp approximately 4500 feet downstream at Prospect Hall Landing. As a participant in the Cape Fear River Basin Association, the instream monitoring requirements as stated above are waived. Should your membership in the agreement be terminated, you shall notify the Division immediately and the instream monitoring requirements specified in your permit shall be reinstated. 2. 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. 3. Daily shall be defined as every day except Saturdays, Sundays, and legal holidays. Instream temperature sampling shall be conducted weekly. 111.- 4. The samples for fluoride shall be taken downstream of the 001 discharge, unless or until, all neutralized Nafion area streams are discharged entirely into the cooling water outfall, 002. Instream fluoride monitoring shall be conducted monthly and shall coincide with effluent monitoring. 5. PFOA (Perfluorooctanoic acid) = The Cape Fear River water intake may be sampled for PFOA on a monthly basis and reported as an upstream parameter in DWQ Form — MR -3. THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS. • Permit NC0003573 A. (4) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) - OUTFALL 001 The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 3.3%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of February, May, August, and November. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR -1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B- for the Chronic Value. Additionally, DWQ Form AT -3 (original) is to be sent to the following address: Attention: Environmental Sciences Section North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical /physic measurements and all concentration/response data, acid be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility duri ng a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number; county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the Nort h Carolina Division of Water Quality indicate potential impacts to the receiving stream; this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organ ism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit NC0003573 A. (5) RE -OPENER CONDITION This permit shall be modified, or revoked and reissued to incorporate additional toxicity limitations and monitoring requirements in the event toxicity testing or other studies conducted on the effluent or receiving stream indicate that detrimental effects may be expected in the receiving stream as a result of this discharge. A. (6) BIOCIDE CONDITION The permittee shall not use any biocide except those approved in conjunction with the permit application. The permittee shall notify the Director in writing not later than ninety (90) days prior to instituting use of any additional biocide used in cooling systems which may be toxic to aquatic life other than those previously reported to the Division of Water Quality. Such notification shall include completion of Biocide Worksheet Form 101 and a map locating the discharge point and receiving stream.