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HomeMy WebLinkAbout201706201102DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0003573
Facility Information
Applicant/Facility Name: I E.I. DuPont de Nemours & Co — DuPont Fayetteville Works
Applicant Address: 22828 NC Hwy 87W, Fayetteville, NC 28306-7332
Facility Address: 22828 NC Hwy 87W, Fayetteville, NC 28306-7332
Permitted Flow (MGD): 2 MGD — WWTP (001)
Type of Waste: Industrial
Facility Classification: III
Permit Status: Renewal
County: Bladen
Miscellaneous
Receiving Stream: Cape Fear River Regional Office: Fayetteville
Stream Classification: C USGS Quad: Duart
303(d) Listed? No Permit Writer: Teresa Rodriguez
Basin/Subbasin: 03-06-16 Date: 12/6/06
Drainage Area (mi2): 4790
Summer 7Q10 (cfs) 791 —
Winter 7Q10 (cfs):
30Q2 (cfs)
Average Flow (cfs): 5676 Lat. 340 50'25" N Long. 781)50'09"W
IWC (%): 17%
Summary:
E.I. DuPont de Nemours & Co submitted a permit renewal application on May 2, 2006 for the renewal of its
NPDES permit. The DuPont Fayetteville Works manufacturing facility includes the Butacite® plant, the
Nafion® plant, the Teflon® plant, and the APFO plant. A new process will be added in 2007 to produce
Polyvinyl Fluoride (PVF) resins. The process wastewaters generated from the new facility will be treated in the
existing treatment plant. DuPont has requested to modify the permit to include the new process wastewaters
generated by the PVF manufacturing and to eliminate outfall 006 from the permit.
anufacturing Facilities:
M
Buticite® Manufacturinq
• DuPontTm Buticite® Interlayer plastic sheeting — This is the final product used in safety glass such as
automobile windshields.
Butacite® is manufactured in large rolls, shipped out in refrigerated trucks to glass manufacturers.
The refrigeration is a requirement as butacite sticks to itself at temperatures above 60°F.
• Polyvinyl butyral (PVB) resin -the resin is shipped to other DuPont facilities for final processing.
Wastewaters generated at this facility are treated in the on-site wastewater treatment plant.
Nafion® Manufacturing
Five products are manufactured at the Nafion® manufacturing facility:
• DuPontTM Nafion® membrane — a plastic film used
in
electrochemical fuel cells;
• Nafion® resins — ultimately extruded into a finished film;
• Nafion® solution — generated during the production of resin;
Fact Sheet
NPDES NC0003573
Page 1
the chloroalkali industry and in
• FLPR vinyl ether monomers — shipped to other DuPont locations to produce various
fluorochemical products such as DuPontTM Teflon®.
• HFPO monomers — shipped to other DuPont locations to produce various fluorochemical products
such as DuPontTM Teflon®.
Wastewaters generated at this facility are neutralized and treated in the on-site WWTP.
Teflon® Manufacturing
DuPontTM Teflon® FEP resin — this resin is used in the electronics industry as a coating for wire, as well as
many other uses.
Wastewaters generated at this facility are treated in the on-site wastewater treatment plant.
Ammonium Perfluorooctanoate (APFO) Manufacturing
APFO is used to produce fluoropolymers and fluorinated telomers that are shipped to other DuPont facilities.
Wastewaters generated in this process are collected and shipped off-site for disposal.
Sentry Glass Plus® Manufacturing
DuPontTM Sentry Glass Plus® - this is an ionoplast interlayer laminate used for laminated safety glass in side,
rear, and overhead automobile windows. It is also used in architectural applications desiring safety glass.
This manufacturing process started in June 2005. No process wastewaters are generated from this process.
Non -contact cooling water is discharged to Outfall 002.
Proposed PVF Manufacturing
This facility will produce Polivinyl fluoride resins (PVF) and is expected to start production in October 2007.
PVF is used in DuPontTM Tedlar® fluoropolymer film manufactured at other DuPont facilities. Tedlar® is used
in the photovoltaic industry in photovoltaic cells and the aircraft industry for interior cabin surfaces, as well as
other uses.
The wastewater generated at this site will be treated at the on-site wastewater treatment plant. Wastewater
from the PVF process will contain unreacted vinyl fluoride, with little or no BOD value. The expected
concentration of vinyl fluoride at outfall 0002 is 0.0035 mg/I.
Non -contact cooling water, condensate and stormwater will be discharged to Outfall 002.
Wastewater Treatment:
Process wastewaters and stormwater from process areas are collected in sumps in the respective
manufacturing areas and conveyed via gravity sewers to the wastewater treatment plant. Sanitary sewage is
conveyed separately to the WWTP.
The treatment system consists of the following:
• Influent pump sump
• 850,000 gallon Equalization basin with two floating submerged mixers
• 250,000 aerated predigester tank
• 1,700,000 gallon aeration tank with a bottom diffused air system with supplemental floating mixer
that injects air through submerged rotors
• Two clarifiers
• 175,000 gallon emergency retention tank
• Dissolved Air Flotation Unit for sludge treatment
• 47,000 gallon sludge storage tank
• Rotary filter for thickening
• Sludge press and steam heated dryer
The treatment system discharges through Outfall 001 to the main discharge channel.
Non -process cooling waters and stormwater are conveyed to ditches and discharged to the main discharge
channel.
The combined flows are discharged through Outfall 002 to the Cape Fear River below Lock and Dam #3.
Fact Sheet
NPDES NC0003573
Page 2
Effluent Guidelines.
DuPont's Fayetteville Works is regulated under the Organic Chemicals, Plastics and Synthetic Fibers
Category, 40 CFR 414 Subpart D. These guidelines apply to products manufactured under SIC codes 2869
and 2821. SIC code 2869 includes Nafion® solution, Vinyl Ether and HFPO monomers manufacturing. SIC
code 2821 includes Teflon® resin, polyvinyl fluoride resin, polyvinyl butyral resin and Nafion® resin
manufacturing. Manufacturing of Nafion membrane, Butacite® sheeting and Sentry Glass plus are classified
as SIC code 3081 which is not regulated by the OCPSF guidelines.
Regulated process flow for Outfall 001 is approximately 1,085,660 gpd. This flow includes the flow from PVF
manufacturing process, which is set to start up in 2007. Average flow for the past 3 years was 0.832 MGD.
EG limits - Subpart D -Thermoplastic Resins. 414.41
rivicess iww - i.uaoen wiuu.
The calculated limits are higher than current limits in the permit. The existing limits will remain in the permit.
Compliance Summary:
Outfall 001
Process Wastewater Treatment Plant
Data reviewed: 1 //1 /2004 - 9/30/2006
riow t3UU :TSS - O&G Temp
MGD 1b/d Ib/d - ` mg/I C
Average 0.0832 63.9 132.8 5.95 27
Maximum 1.275 2981 349.3 28. 30
Minimum 0.078 < 2.6 8.7 < 5 9
40 CFR 414 Subpart (Parameters -Monitoring was waved based on a demonstration made by the Permittee
in accordance to 40 CFR 122.44(a)(2)(i). The permit application includes a pollutanf analysis -for these
parameters. No parameters were detected.
Notices of Violation -The facility received two NOVs: March 2005 for BOD monthly average and daily max
and March 2006 for BOD daily max.
Outfall 002
Combined cooling waters, stormwater and process WWTP effluent
Data reviewed: 1//1/2004 - 9/30/2006
Avera e
Maximum
Minimum
Flow
Effluent Limitations
Effluent Limitations
Domestic
WW
Proposed limits
MGD
12.61
concentration
Mass limits
(mass
limits)
mass limits`'
Parameter
Maximum
MaximumDaily
Monthly
5030
Monthly
Daily
Monthly
Daily
Monthly
19
Daily
Average
Maximum
Average
Maximum
Average
Maximum
Average
{mg/I)
(Ib/day)
(Ib/day)
(Ib/day)
(Ib/day)
(Ib/day)
(Ib/day)
mg/1
BOD
64
24
579.5
217.3
3
2
582.5
219.3
TSS
130
40
1177.1
362.2
3
2 1
1180.1
364.2
rivicess iww - i.uaoen wiuu.
The calculated limits are higher than current limits in the permit. The existing limits will remain in the permit.
Compliance Summary:
Outfall 001
Process Wastewater Treatment Plant
Data reviewed: 1 //1 /2004 - 9/30/2006
riow t3UU :TSS - O&G Temp
MGD 1b/d Ib/d - ` mg/I C
Average 0.0832 63.9 132.8 5.95 27
Maximum 1.275 2981 349.3 28. 30
Minimum 0.078 < 2.6 8.7 < 5 9
40 CFR 414 Subpart (Parameters -Monitoring was waved based on a demonstration made by the Permittee
in accordance to 40 CFR 122.44(a)(2)(i). The permit application includes a pollutanf analysis -for these
parameters. No parameters were detected.
Notices of Violation -The facility received two NOVs: March 2005 for BOD monthly average and daily max
and March 2006 for BOD daily max.
Outfall 002
Combined cooling waters, stormwater and process WWTP effluent
Data reviewed: 1//1/2004 - 9/30/2006
Avera e
Maximum
Minimum
Flow
BOD
COD
Fluoride
TP
TN
MGD
12.61
mg/I
57.5
mg/I
52.0
Ib/day
834
mg/I
16.2
mg/I
2.7
22.24
212
102.0
5030
302.0
26.5
2.96
<2
<25
19
<0.1
0.5
Whole Effluent Toxicity -The permit requires a quarterly chronic test at 3.3 %. The facility passed all the tests
for the period of Feb 2002 to Aug 2006.
Notices of Violation -There were no NOVs for this outfall.
Priority Pollutant Analysis - No parameters were detected in the PPA above the allowable concentrations.
Fact Sheet
NPDES NC0003573
Page 3
Instream data review:
There are monitoring stations in the Cape Fear River upstream (138301000) and downstream (138302000) of
the discharge. Data from the monitoring stations don't show water quality concerns.
68301000 - U stream station at Lock & Dam #3
m
a ECO
ro L� z z O
LL o Z NO ~
0 U U) F- z
Mg/1 , SU pmhos/cm /100 ml mg/1 NTU mg/1 mg/1 mg/1 mg/1
A v6 Ma�irr>urt� 8.3 6.9 154.2 43.9 21.1 15.2 0.1 0.7 0.7 0.2
Minirrram 12.8 7.7 261.0 3000.0 124.0 33.0 0.5 1.2 1.4 0.3
1\4 IN Av e 5.7 5.9 81.0 6.0 3.9 4.5 0.0 0.1 0.4 0.1
138302000 -Downstream station near Tolarsville
SUMMARY OF PROPOSED CHANGES:
• Outfall 006 was eliminated from the permit. This outfall authorized the discharge of wastewaters from
the Nafion® manufacturing process but current procedure is to send the wastewater to the WWTP
for treatment. DuPont requested to eliminate the outfall from the permit as they will continue to send
the wastewater to the WWTP.
• The Supplement to Cover Sheet includes authorization to discharge treated wastewater from the
PVF process. The process will start up in late 2007.
Fact Sheet
NPDES NC0003573
Page 4
Draft Permit to Public Notice: December 20, 2006
..Permit Scheduled to Issue: � February 12, 2007
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact Teresa
Rodriguez at (919) 733-5083 ext. 553.
NAME: �� DATE: ��
REGIONAL OFFICE COMMENTS
NAME:
SUPERVISOR
TE: � � ' .� ij ' ��.
TE: I—�'—� 7
Fact Sheet
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FACILITY DuPont -Fayetteville
OCPSF Flow 1.08566 MGD Outfall 001: How Is based on processes only
7010s 791 cis
Qavg 5676 cis
Permitted Flow 2 MGD Human Hlth Human Hlth Allowable Allowable
Limit Limit Federal or Standard Standard Allowable Allowable Aquatic Life Human Hlth Limit Daily Monthly
Daily Monthly Daily Monthly State Aquatic Organisms cone. Aquatic cone Organisms Based Max Avg.
max avg max avg Life Life Organisms on:
Parameter ug/I ug/I #/d #/d stdrd pg/I jug/] Ng/I Acyl #/day #/day #/day
Acenaphthene 59 22 0.534 0.199 Federal no stdrd 990.00 no sidrd 253599.68 no stdrd 4226 661 OCPSF 0,534 Ii/clay 0,199
Acenaphthylene 59 22 0.534 0.199 Federal no stdrd no sidrd no stdrd no sidrd no stdrd no stdrd OCPSF 0,534 #/day 0 199
Acrylonitrile (c) 242 96 2.191 0.869 Federal no sidrd 0.25 no stdrd 457.99 no stdrd 7.633 OCPSF 2,191 #/day 0,869
Anthracene 59 22 0.534 0.199 Federal no stdrd 40000.00 no stdrd 10246451.61 nostdrd 170774194 OCPSF 0,534 #/day 0.199
Benzene (c) _ 136 37 1.231 0.335 State no stdrd -' `71.40 no stdrd 130802.50 no stdrd 2180.042 OCPSF 1,231 #/day 0,335
Benzo(a)anthracene (c, P, 59 22 0.534 0.199 Federal no stdrd 0.018 no stdrd 32.98 no stdrd 0.550 OCPSF 0,534 #/day 0,199
3,4-Benzofluoranthene(c, 61 23 0.552 0.208 Federal no stdrd 0.0311 no stdrd 56.97 no stdrd 0.950 OCPSF 0.552 #/day 0,208
Benzo(k)fluoramhene (c,P 59 22 0.534 0.199 Federal no sidrd 0.0180 no stdrd 32.98 no stdrd 0.550 OCPSF 0.534 #/day 0 199
Benzo(a)pyrene (c, PAH) 61 23 0.552 0.206 Federal no stdrd 0.0311 no stdrd 56.97 no sidrd 0.950 OCPSF 0,552 #/day 0,208
Bis(2-ethylhexyl) phthalatE 279 103 2.526 0.933 Federal no stdrd 2.20 no stdrd 4030.33 no stdrd 67.172 OCPSF 2,526 #/day 0,933
Carbon Tetrachloride (c) 38 18 0.344 0.163 State no stdrd 4.42:x: - no stdrd 8097.30 no stdrd 134,955 OCPSF 0,344 #/day 0,163
Chlorobenzene 28 15 0.254 0.136 Federal no stdrd 21000.00 no stdrd 5379387.10 no stdrd 89656 452 OCPSF 0.254 #/day 0.136
Chloroethane 268 104 2.427 0.942 Federal no stdrd no sidrd no sidrd no stdrd no stdrd no sidrd OCPSF 2,427 #/day 0,942
Chloroform (c) 46 21 0.417 0.190 Federal no stdrd '':470.00 no sidrd 861024.84 no sidrd 14350.414 OCPSF 0,417 Ji/clay 0,190
2 -Chlorophenol 98 31 0.887 0.281 Federal no stdrd 150.00 no stdrd #REFI no stdrd #REFI #REFI #REFI #REFI #REFI
Chrysene (c, PAH) 59 22 0.534 0.199 Federal no sidrd 0.0180 no stdrd 32.98 no stdrd 0.550 OCPSF 0.534 #/day 0.199
Dl -n -butyl phthalate 57 27 0.516 0.244 Federal no sidrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.516 #/day 0,244
1,2 -Dichlorobenzene 163 77 1.476 0.697 Federal no stdrd 17000.00 no stdrd 4354741.94 no sidrd 72579.032 OCPSF 1.476 it/day 0,697
1,3 -Dichlorobenzene 44 31 0.396 0.281 Federal no stdrd 960.00. no stdrd 245914.84 no stdrd 4098 581 OCPSF 0,398 #/day 0,281
1,4 -Dichlorobenzene 28 15 0.254 0.136 Federal no stdrd 2600.00'P: no stdrd 666019.35 no sidrd 11100 323 OCPSF 0,254 #/day 0,136
1,1-Dichloroethane (c) 59 22 0.534 0.199 Federal no stdrd nostdrd- no stdrd no stdrd no stdrd nostdrd OCPSF 0534 #/day 0,199
1,2-Dichloroethane (c) 211 68 1.910 0.616 Federal no sidrd 3.70 no stdrd 6778.28 no sidrd 112.971 OCPSF 1,910 #/day 0.616
1,1-Dichloroethylene (c) 25 16 0.226 0.145 Federal no stdrd c-3.20- no stdrd 5862.30 no stdrd 97 705 OCPSF 0,226 #/day 0,145
1,2-trans-Dichloroethylene 54 21 0.489 0.190 Federal no stdrd 140000.00 nostdrd 35862580.65 no stdrd 597709677 OCPSF 0.489 #/day 0190
2,4-Dichlorophenol 112 39 1.014 0.353 Federal no stdrd 290.00 no stdrd #REFI no stdrd #REFI #REFI #REFI #REFI #REFI
1,2-Dichloropropane 230 153 2.083 1.385 Federal no sidrd 15.00 no sidrd 3842.42 no stdrd 64.040 OCPSF 2,083 #/day 1,385
1,3-Dichloropropylene (c) 44 29 0.398 0.263 Federal no stdrd 1700.00 no stdrd 3114345.16 no stdrd 51905 753 OCPSF 0,398 #/day 0,263
Diethyl phthalate 203 81 1.838 0.733 Federal no stdrd 44000.00 no stdrd 11271096.77 no stdrd 187851 613 OCPSF 1,838 #/day 0,733
2,4 -Dimethylphenol 36 18 0.326 0.163 Federal no stdrd 850.00 no stdrd 217737.10 no stdrd 3628 952 OCPSF 0.326 #/day 0.163
Dimethyl phthalate 47 19 0.426 0.172 Federal no stdrd 1100000.00 no stdrd 281777419.35 nostdrd 4696290.323 OCPSF 0.426 #/day 0.172
4,6-Dinitro-o-cresol (2 -Met 277 78 2.508 0.706 Federal no stdrd 280.00 no sidrd 71725.16 no sidrd 1195 419 OCPSF 2,508 #/day 0,706
2,4-Dinitrophenol 123 71 1.114 0.643 Federal no stdrd 5300.00 no sidrd 1357654.84 no sidrd 22627 581 OCPSF 1 114 #/day 0,643
2,4-Dinitrotoluene (c) 285 113 2.581 1.023 Federal no stdrd 3.40 no stdrd #REFI no sidrd #REFI #REFI #REFI #REFI #REFI
2,6-Dinitrotoluene (C) 641 255 5.804 2.309 Federal no stdrd - no stdrd no sidrd no sidrd no stdrd no stdrd OCPSF 5,804 #/day 2,309
Ethylbenzene 108 32 0.978 0.290 AQ/NOEC 325.000 '%29000.00.' 83252.42 7428677.42 1387.540 123811290 OCPSF 0,978 #/day 0,290
Flouranthene 68 25 0.616 0.226 Federal no sidrd 140.00 no stdrd 35862.58 nostdrd 597.710 OCPSF 0,616 #/day 0,226
Fluorene 59 22 0.534 0.199 Federal no stdrd 5300.00 no stdrd 1357654.84 no stdrd 22627581 OCPSF 0,534 #/day 0199
Hexachlorobenzene(c) 28 15 0.254 0.136 Federal no stdrd 2.90E-04 no stdrd 0.53 no stdrd 885E-03 CHRONIC 0,531 NgA
Hexachiorobutadlene (c) 49 20 0.444 0.181 Federal no stdrd 18.00 no sidrd 32975.42 no stdrd 549.590 OCPSF 0 444 #/day 0 181
Hexachloroethane (c) 54 21 0.489 0.190 Federal no stdrd 3.30. - no stdrd 6045.49 no stdrd 100 758 OCPSF 0,489 #/day 0,190
Methyl Chloride 190 86 1.720 0.779 Federal no sidrd no stdrd -- no stdrd no stdrd no stdrd no sidrd OCPSF 1,720 #/day 0,779
Methylene Chloride (c) 89 40 0.806 0.362 Federal no sidrd 590.00 no stdrd 1080860.97 no stdrd 18014 349 OCPSF 0.806 #/day 0,362
Naphthalene 59 22 0.534 0.199 Federal no sidrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0,534 #/day 0,199
Nitrobenzene 68 27 0.616 0.244 Federal no stdrd 690.00 no sidrd 176751.29 no stdrd 2945 855 OCPSF 0,616 #/day 0,244
2-Nitrophenol 69 41 0.625 0.371 Federal no sidrd :no stdrd no stdrd no stdrd no sidrd no stdrd OCPSF 0,625 #/day 0,371
4-Nllrophenol 124 72 1.123 0.652 Federal no stdrd no stdrd no sidrd no stdrd mo stdrd no stdrd OCPSF 1.123 #/day 0.652
Phenanthrene 59 22 0.534 0.199 Federal no stdrd no sidrd no stdrd no stdrd no sidrd no sidrd OCPSF 0 534 #/day 0 199
Phenol 26 15 0.235 0.136 Federal no stdrd 1700000.00 no stdrd 435474193.55 no stdrd 7257903 226 OCPSF 0,235 #/day 0,136
Pyrene 67 25 0.607 0.226 Federal no stdrd 4000.00 no stdrd 1024645.16 no stdrd 17077 419 OCPSF 0,607 #/day 0,226
Tetrachloroethylene (c) 56 22 0.507 0.199 Federal no stdrd 3.30 no sidrd 6045.49 no stdrd 100.758 OCPSF 0,507 #/day 0,199
Toluene 80 26 0.724 0.235 Stale/AQ 11.000 200000.00 2817.77 51232258.06 46.963 853870966 OCPSF 0,724 #/day 0235
1,2,4-Tdchlorobenzene 140 68 1.268 0.616 Federal no stdrd 940.00 no stdrd 240791.61 no stdrd 4013194 OCPSF 1,268 #/day 0,616
1,1,1 -Trichloroethane 54 21 0.489 0.190 Federal nostdrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.489 #/day 0.190
1,1,2-tdchloroethane (c) 54 21 0.489 0.190 Federal no stdrd 16.00 no stdrd 29311.48 no stdrd 488,525 OCPSF 0,489 #/day 0,190
Trichlororethylene (c) 54 21 0.489 0.190 State no stdrd 30.00 no stdrd 54959.03 no stdrd 915.984 OCPSF 0,489 #/day 0,190
Vinyl Chloride (c) 268 104 2.427 0.942 State no stdrd 530.00 no stdrd 970942.90 no stdrd 16162.382 OCPSF 2.427 #/day 0.942
"Total Chromium 2770 1110 0.000 0.000 State 50.000 no stdrd 12808.06 no stdrd 213.468 no stdrd OCPSF 0.000 #/day 0.000
" Total Copper 3380 1450 0.000 0.000 Action level 7.000 no sidrd 1793.13 no stdrd 29.885 no sidrd OCPSF 0.000 #/day 0.000
Total Cyanide 1200 420 0.000 0.000 State 5.000 no stdrd 1280.81 no stdrd 21.347 no stdrd OCPSF 0.000 #/day 0.000
" Total Lead 690 320 0.000 0.000 State 25.000 no sidrd 6404.03 no stdrd 106.734 no stdrd OCPSF 0.000 #/day 0.000
" Total Nickel 3980 1690 0.000 0.000 Stale 88.000 no stdrd 22542.19 no stdrd 375.703 no stdrd OCPSF 0.000 #/day 0.000
Total Zinc' 2610 1050 0.000 0.000 Action level 50.000 50.00 12808.06 12808.06 213.468 213.466 OCPSF 0.000 #/day 0.000
'Total Zinc for Rayon Fiber Manufacture "Metals should only be limited if Total metal bearing wasteilor 01
00
that uses the viscose process and Acrylic process contains metal bearing wasleflow.
Fiber Manufacture that uses zinc Cyanide should only be limited If Total cyanide bearing tvastef 0.00
chloridelsolvent process is 6,796 ug/L and process contains cyanide bearing wasleflow.
3,325 ug/L for maximum for any one day
and maximum for monthly average, respectively.
12/12/2006 1
[Fwd: [Fwd: PFOA]]
Subject: [Fwd: [Fwd: PFOA]]
From: Kent Wiggins <kent.wiggins@ncmail.net>
Date: Wed, 16 May 2007 11:51:26 -0400
To: Teresa Rodriguez <teresa.rodriguez@ncmail.net>
CC: Pat Donnelly <Pat.Donnelly@NCMail.Net>
Teresa,
We have done a fair amount of research on the PFOA issue. There is currently no officially recognized
method for this analysis. We discussed the analysis with our auditors and were able to find one lab that
advertises the capability. Please see Pat Donnelly's attached email.
Please let me know if you need anything else.
Kent
Subject: [Fwd: PFOA]
From: Pat Donnelly <pat.donnelly@ncmail.net>
Date: Wed, 16 May 2007 10:37:56 -0400
To: Kent Wiggins <Kent.Wiggins@ncmail.neU
CC: Dana Satterwhite <dana.satterwhite@ncmail.neU, Gary Francies <Gary.Francies@ncmail.net>
Kent, I believe this is where this issue stands. NC certified Lab #358, STL Denver advertises PFOA
`-- --r--- - —..___ _-..-
analysis on their WEB site. They also hold NELAP certification. I'm sure there are other labs that also
do PFOA analysis. There's no currently promulgated EPA method for PFDA. Pat
Subject: PFOA
From: Teresa Rodriguez <teresa.rodriguez@ncmail.net>
Date: Wed, 16 May 2007 10:13:23 -0400
To: kent.wiggins@ncmail.net
CC: pat.donnelly@ncmail.net, Gil Vinzani <gil.vinzani@ncmail.net>
Kent, we talked a couple of weeks ago about the situation with the DuPont permit and the monitoring of PFOA
but I'm not sure we determined what they need to do regarding lab certification. We are ready to issue the
DuPont permit which will include monitoring for PFOA. Is there anything we can include as a footnote or in
the letter to DuPont regarding the analytical method or requirements for lab certification?
Thanks,
Teresa
Teresa Rodriguez, P.E.
Division of Water Quality
EAST NPDES Program
919-733-5083 ext. 553
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11NITE® STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
t I I) 2Q01
Ms. Teresa Rodriguez
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 276994617
SUBJ: Draft NPDES Permit
DuPont Fayetteville Works - NPDES No. NC0003573
Dear Ms. Rodriguez:
In accordance with the EPA/NCDENR MOA, we have completed review of the draft
permit referenced above and have no comments. We request that we be afforded an additional
review opportunity only if significant changes are made to the draft permit prior to issuance, or if
significant comments objecting to the draft permit are received. Otherwise, please send us one
copy of the final permit when issued.
If you have any questions, please call me at (404) 562-9304.
.�iu�c7'e y �
Marshall Hyatt, Environmental Scientist
Permits, Grants, and Technical Assistance Branch
Water Management Division
Internet Address (URL) ®http://v�vw✓.epa.gov
Recycled/Recyclable ®Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
Draft NPDES Permit NC0003573
Subject: Draft NPDES Permit N00003573
From: Michael E Johnson <Michael.E.Johnson@USA.dupont.corry
Date: Tue, 2 Jan 2007 10:29:22 -0500
To: teresa.rodriguez@ncmail.net
Teresa:
I received the draft NPDES permit you sent me.
I have two questions for you:
Question 1: I noticed that on the Outfall 002 page, the frequency of
instream monitoring of conductivity changed from weekly to monthly, yet all
the other instream parameters stayed at the weekly frequency. Was the
conductivity frequency inadvertently .changed to monthly and should have
remained as weekly?
� r.
Question 2: We are members of the Middle Cape Fear River Basin Association
(MCFRBA) which is a coalition of dischargers in the middle section of the I�/_�,�
Cape Fear River basin. Through the MCFRBA we contract a commercial � �i�'� /'
laboratory to perform instream monitoring of the river at various locations � ��
as dictated by an MOA between DWQ and MCFRBA. As such, under our existing
NPDES permit, the instream monitoring requirement is waived as long as we /
remain members of the MCFRBA. That waiver was specified in Note 1 in
condition A(5).
In the draft you sent me, I cannot find this waiver. Was this an advertent
omission, or has DWQ changed their policy to allow coalition monitoring to
satisfy the instream monitoring requirement?
Let me know the answers to these questions and whether or not I need to
formally send these as official comments to your office.
Regards,
Mike
Michael E. Johnson
Environmental Manager
DuPont Company
Fayetteville Works
(910) 678-1155
This communication is for use by the intended recipient and contains
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in whole or in part, is strictly prohibited. Please notify the sender by
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1/4i2nm �•nt p�
,NORTH CAROLINA
Cumberland County
Public Notice
S'FA1T? OF
NOR1H CAROLINA
ENVIRONMENTAL.
MANAGEMENT
COKMISS10N/NPDES -UNIT
161.7 MAIL SERVICE
CENTER
RALRIGFI NC
27699-1b11
NOTIFICATION OF INTENT
TO ISSUE A NPDES
WASTEWATER PERMIT
)n the basis of thorough.
tuff review- and application
f NC General, Statute
and regulations, the North
Carolina Environmental
Management Commission
drooppooses to issue a National
YollmAur Discharge Elbows.
tion System (NPDES) .waste -
water di.FcharRe. hermit to
effective 45 days fr
om the
publi;h date of.dtis nodge:
Written comments regardingg
the proposed. permit .will be
accepted uutil 30 days after
the piublish Osie 'of tbis+ lto-
tice. All comments received
prior to that date ars consid
eyed to the fnlal detM ina.
tions .regarding. the pro-
posed Demur. The Director
9P the NC Division, u1 Water
Quality may decide to boll a
public meed
, for the pro -
posed permit shouldthe Dim
vimon receive a significant
degree ofpiubuc init@jest.
Cop�'es of the draft Permit
Ing other $upporting tnfor;
mallon
on. useJ '.to deter -
mine conditions present in
fie. drag perrpit arc ayailahle
spun request and payment
of the .cosis ofrzprodnction.
Mail commenu and/or re-
quests for information to :the
NC Diyisibn of Water Quality
at the above address or call
the; Point. Source Branch at
;919) 733-5983; extension.
563. Comments can also be
e-mailed to:
Carolyn,Btyant@pomaii,net
Please include the :NPDFS
permit number (attached) in
any communication. Inter-
e4ted poisons may also visit
the Division of WaterQuality
at 512 N. Salisbury Street,
Raleigh NC 27664-1148 be-
Iween the hours of 8:00 a.m.
and 5,:00 p.m. to review io-
formation on. file,
Dupont Fayetteville Works,
225281mlighwayy 87 W.,
Fayetteville, NC 28106,
Bladen Cost" has a lied
for teneWal of its NPDIff dis-
mre
Cape .Fear River. interrtal
antfall b01
oischar es a
mezinmm df
2,0. MGD of
treated process
wastewater.
No pammeters
ate .currently
water
quality
limite it 7;his
discharge
may
impact form
allocation of
the+
receiving
stream
120
829200
AFFIDAVIT OF PUBLICATION
A
eierore the unaersignea, a Nary otI'unrnc of said County and s a et du
commissioned and authorized to administer oaths, affirmations, etc.,
personally appeared. CINDY L. OROZCO
Who, being duly sworn or affirmed, according to law, doth depose and say
that he/she is LEGAL SECRETARY
of THE FAYETTEVILLE PUBLISHING COMPANY, a corporation organized
and doing business under the Laws of the State of North Carolina, and
publishing a newspaper known as the FAYETTEVILLE OBSERVER, in the
City of Fayetteville, County and State aforesaid; and that as such he/she
makes this affidavit; that he/she is familiar with the books, files and
business of said Corporation and by reference to the files of said
publication the attached advertisement of CL Legal Line
DUPONT/NC0003573
of NCDENR/DWQ/NPDES
Us inserted in the aforesaid newspaper in space, and on dates as follows:
12/27/2006.
and.at the time of such. publication The. Fayetteville Observer was a
newspaper meeting all the requirements and qualifications prescribed by
Sec. No. 1-597 G.S. of N.C.
The above is correctly copied from the books and files of the aforesaid
corporation and publication.
T
LEGAL SECRETARY
Sworn or affirmed to, and subscribed before me, this 4 day
January, A.D., 2007.
In Testimony Whereof, I have hereunto set my -hand and affixed my
official seal, the day and year aforesaid.
My commission expires 9th day of March, 2009,
MAIL TO: NCDENR/DWQ/NPDES
1617 MAIL SERVICE CENTER, ,
RALEIGH, NC 27699
0000829200
Ms. Teresa Rodriguez
NCDENR Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699 - 1617
�,� (� ,
1 __...
- ��;�: I � t.t.��.itJ
r r �` t(ur�;Ci�'
'''�+ i
SUBJECT: NPDES Permit Renewal Application Addendum
Revised Supplemental Information
NPDES Permit No. NC0003573
Dear Ms. Rodriguez:
�uPont Fluoroproducts
22828 NC Highway 87 W
(Fayetteville, NC 28306-7332
December 7, 2006
Enclosed you will find a revised Supplemental Information document that describes the
proposed changes with the construction of a new manufacturing unit that will produce Polyvinyl
Fluoride (PVF) polymer resins. It has been determined that the preferred means of controlling
solids from the PVF unit is via the site's central wastewater treatment plant. Accordingly, treated
wastewater from this new unit will be discharged through and monitored at Outfa11001.
A revised water balance sheet is enclosed which reflects the above treatment change.
Should you have any questions, please feel free to call me at (910) 678-1155.
Sincerely,
Michael E. Johnson
Environmental Manager
Enclosures
E.I. du Pont de Nemours and Company
DuPont Company — Fayetteville Works
NPDES Permit No. NC0003573
Supplemental Information (Revised)
Revised Supplemental Information — Permit Renewal Application — December 7, 2006
Proposed Changnes in Operations
PVF Manufacturing Facility: The DuPont Company —Fayetteville Works has been selected as
the location for the DuPontTM Polyvinyl Fluoride (PVF) manufacturing process. The
manufacturing facility is in the process of being designed, and will produce PVF polymer resins.
PVF resin to be manufactured at the Fayetteville plant is used in DuPontTM Tedlar®
fluoropolymer film business. Tedlar® film is manufactured at other DuPont site location (not
the Fayetteville plant). Tedlar® is used in the photovoltaic industry in photovoltaic cells and the
aircraft industry for interior cabin surfaces, as well as many other uses. This new facility
construction will be completed in August 2007 and begin start up in October 2007.
The manufacturing facility will be located near the existing Teflon® FEP resin manufacturing
area. This process will produce polyvinyl fluoride (PVF) resin (CAS No. 2498144-4).
The process wastewater from the PVF Manufacturing Facility will be conveyed to the site's
central wastewater treatment plant, which will properly control any solids that are discharged
from the process. The treated wastewater from the PVF Manufacturing Facility will be
discharged through and monitored at Outfall 001.
A suggested change to the language of the current permit's narrative in the "Supplement To
Permit Cover Sheet" that would accommodate the new PVF Manufacturing Facility follows:
1. Continue to operate existing wastewater treatment facilities consisting of:
• equalization; (etc)
2. Discharge treated process wastewater fr
om Butacite®, Nafion®, PVF, and Teflon®
PMDF, process stormwater, sanitary wastewater, and co -neutralized regenerate from said
treated facilities through internal outfall 001;
The process wastewater is expected to contain unreacted vinyl fluoride (CAS No. 00075-02-5).
The anticipated quantity of vinyl fluoride from the PVF Manufacturing Facility is 0.312 pounds
per day. This quantity would equate to approximately 0.04 mg/L vinyl fluoride at Outfall 001
and 0.0035 mg/L vinyl fluoride at Outfall 002.
Finally, non -contact cooling, condensate, and stormwater from the PVF Manufacturi
ng Facility
will be discharged directly to Outfa11002 via the site's Woodlined Ditch6
Date: November 275 2006
To: Teresa Rodriguez
Environmental Engineer, Central Office
Thru: Belinda Henson K /t ,
Regional Supervisor, Fayetteville Regional Office
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
From: Marls Brantley
Environmental Chemist, Fayett ille Regional Office
Alan W. Klimek, P.E. Director
Division of Water Quality
DEC 1 2006
Subject: Amendment to the Dupont Staff report for the NPDES Permit Renewal
Dupont's Fayetteville Worlcs will be adding a new manufacturing process in the fall of 2007. The
manufacturing unit will produce Polyvinyl Fluoride (PVF) polymer resins. Dupont has determined that
the preferred means of controlling solids from the PVF unit is a new clarifier, which will be dedicated to
the PVF wastewater. The discharge from this clarifier will be to the existing Outfall 001.
This design replaces the original submittal's description of the PVF treated wastewater being discharged
through and monitored at Outfall 006,
It is the recommendation of the Fayetteville Regional Office that NPDES Permit No. NC0021636 be
issued for the wastewater treatment plant. The subject application for permit renewal should be
processed in keeping with basinwide strategy.
One
NorthCarolina
�lltlilYl��f
North Carolina Division of Water Quality 225 Green Street -Suite 714 Fayetteville, NC 25301 Phone (910) 486-1541 Customer Service
Internet: www.ncwaterqualityorg Fax (910)486-0707 1-877-623-6745
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post
Consumer Paper
LAW
13,(
Form 2C, Part III B:
WATER BALANCE (Revised 12/07/06)
DuPont Company - Fayetteville Works
Flows Unit: Gallons per Day
Basis: All Production Manufacturing, using
DIVISION OF WATER QUALITY
May 30, 2006
MEMORANDUM Ip IA
TO: G 1,Vinzani, Supervisor
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
FROM: Mark Brantley, Environmental Chemist �� %�
Fayetteville Regional Office
THRU: Belinda S. Henson, Water Quality Supervisor 4LY
Fayetteville Regional Office
SUBJECT: NPDES Staff Report and Recommendations
NPDES Permit No. NC0003573
DuPont WWTP
Bladen County
Please find attached the staff report and recommendations ofthe Fayetteville Regional Office
concerning the renewal of subject NPDES Permit.
If you have any questions or require any further information, please advise:-;� ��..
Attachment
SOC PRIORITY PROJECT: YES_ NO X
If Yes, SOC No.
To: Permits and Engineering Unit
Surface Water Protection Section
Attention: Gil Vinzani
Date: _ May 30, 2006
"i tf
r
NPDES STAFF REPORT AND RECOMMENDATION
COUNTY* Bladen
�
Permit No. NC 0003573It
�
PART I -GENERAL INFORMATION
1. Facility and Address: DuPont Fayetteville Works
22828 NC Hwy 87 W
Fayetteville, NC 28306
3.
C!
5
6.
fll
E
9.
Date of Investigation:
Report Prepared by:
May 18, 2006
Mark Brantley, Environmental Chemist
Persons Contacted and Telephone Number:
It
,
Robert Geddie, ORC
910-678-1219
Michael Johnson, Environmental Manager
Fayetteville Works
910-678-1155
Directions to Site: This facility is located at the Bladen -Cumberland County line, between
Highway 87 and the Cape Fear River.
Discharge Point(s), List for all discharge points:
Latitude: 340 49'5211
Longitude: 78°
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map.
U.S.G.S. Quad No. H 23 -SE U.S.G.S. Quad Name: Duart, NC
Site: Land available for expansion and upgrading: YES, DuPont owns approximately 2,600
acres at this site.
Topography and relationship to flood plain: Relatively flat.
Location of nearest dwelling: None within 1,0001
Receiving stream or affected surface waters: Cape Fear River
PART I - GENERAL INFORMATION -(continued)
bM
cA
Classification: Class C
River Basin and Subbasm No.: Cape Fear River Basin 03 - 06 - 17
Describe receiving stream features and pertinent downstream uses:
The flow from the combined waste discharge from this facility flows through a wood lined
channel installed as an effluent and storm water conveyance. This combined flow
discharges over a fabricated formed concrete lined ditch until velocities are diminished
and from there to the remainder of the effluent channel. Under normal (dry) conditions,
this facility produces the flow in the effluent channel. The Cape Fear River is located
approximately 2,500 feet downstream. (The discharge point has historically been
indicated as the main stem of the Cape Fear River.)
PART II -DESCRIPTION OF WASTES AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted: 2.0 MGD
b. What is the current permitted capacity of the Wastewater Treatment facility? 2.0 MGD
c. Actual treatment capacity of the current facility (current design capacity). 2.0 MGD
d. Dates) and construction activities allowed by previous Authorizations to Construct issued
in the previous two (2) years. N/A
e. Please provide a description of existing or substantially constructed wastewater treatment
facilities:
Process wastewater and storm water 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 flow
rate of the WWTP is 2.0 MGD, with an actual average flow rate of approximately one
MGD.
This process wastewater is commingled in the WWTP Influent Sump where it is pumped
to an 850,000 -gallon Equalization Basin. The Equalization Basin is mixed with two
floating mixers. Three floating surface aerators in the basin cool and aerate the incoming
wastewater.
A 175,000 -gallon Emergency Retention Tank is available for temporary storage of the
wastewater which may need additional treatment or acclimation in the WWTP activated
sludge process at a controlled rate that allows for proper biological treatment.
Wastewater fr
om the Equalization Basin is normally pumped to a 250,000 -gallon
Predigester Tank in which initial biological activity with the WWTP activated sludge
begins. The Predigester Tank is aerated. The partially treated wastewater from the
Predigester Tank is pumped to a 1,700,000 -gallon Aeration Tank.
The Aeration Tank is the site of the majority of the biological activity. The Aeration Tank
is aerated primarily by a diffused air system located in the bottom of the tank. The tank
can have supplemental aeration via a floating Biomixer that injects air through submerged
rotors. (However this system is currently broken and has been removed from the aeration
tank. Portable blowers have been brought in to aerate the tank.)
2
4.
PART H - DESCRIPTION OF WASTES AND TREATMENT WORKS -(continued)
The biologically treated wastewater is then sent to two in -ground clarifiers (119,000
gallons and 168,000 gallons respectively) in parallel. The clarified treated effluent is
discharged to and through Outfall 0014
The wasted sludge is sent to a Dissolved Air Floatation (DAF) unit, then to a 47,000
gallon Sludge Storage Tank, and finally to Rotary Filter for thickening. The thickened
sludge is dewatered in a Sludge Press, and can be dried in a steam -heated dryer for
additional moisture removal. The dewatered and/or dried sludge is transported off-site to
a commercial Subtitle D landfill.
Non -contact process cooling water and non -process storm water 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 maximum
30 -day average flow was 16.3 MGD during the period from 2005-2006. Flow variability
at Outfall 002 is from 3.0 to 18.6 MGD, however, flow can consistently be in the 16.3
MGD range.
£ Please provide a description of proposed wastewater treatment facilities:
Please see Attachment A for a detailed description for "Proposed Changes in Operations"
g. Possible toxic impacts to surface waters: N/A
h. Pretreatment Program (POTWs only):
Tn development Approved
Should be required Not needed X
Residuals handling and utilizing/disposal scheme:
a. If residuals are being land applied, please specify DWQ Permit No.
Permit Number
Residual Contractor:
Telephone
b. Residuals stabilization: PSRP PFRP Other
c. Landfill: The dewatered and/or dried sludge is transported off-site to a commercial
Subtitle D landfill. This sludge is currently being disposed of at the
Waste Industries' Sampson County Landfill near Roseboro, NC.
d. Other disposal/utilization scheme (specify):
Treatment plant classification (attach completed rating sheet): Grade III
SIC Code(s):
Primary.
Secondary
Main Treatment Unit Code:
PART III- OTHER PERTINENT INFORMATION
1
2.
3
4.
5
Is this facility being constructed with Construction Grant Funds or are any public monies involved
(municipals only)?
Special monitoring or limitations (including toxicity) requests:
Monitoring and limits should be in keeping with basinwide strategy.
Important SOC, JOC, or Compliance Schedule Dates (please attach): N/A
Date
Submission of Plans and Specifications.................................................... N/A
Begin Construction, . a a 0 0 * S 0 a a 6 a 0 a 0 a 6 0 W 0 0 5 0 9 0 0 0 0 T 0 0 9 1 d 0 a 9 1 4 4 4 8 a 1 0 a 0 0 a a a 0 0 0 d 0 a 8 * a 0 0 0 a V 0 0 9 N/A
Complete Construction, . 0 a a 0 B 0 a 0 a 0 a a 0 a & a * a 0 6 0 0 * 5 9 9 0 0 N/A
Alternative Analysis Evaluation: Has the facility evaluated all of the nondischarge options
available? Please provide regional perspective for each option evaluated.
Spray Irrigation: Not practical.
Connection to Regional Sewer System: None Available.
Subsurface: Not practical.
Other disposal options: None lrnown.
Other Special Items: There are 2 items of interest the Fayetteville Regional Office would like
address.
1. The compound commonly known as "C8" (ammonium
perfluorooctanoate.) has been in the media quite frequently in the
recent past. This compound is currently manufactured only at the
Fayetteville Dupont Works. It is noted in Dupont's application that
the APFO Manufacturing site is where this chemical is made. It is
also noted in the application (Attachment B) that all wastewater
generated from this manufacturing facility is collected and shipped
off-site for disposal. No process wastewater from this manufacturing
facility is discharged to the site's biological WWTP or to the Cape
Fear River. Due to C8 being detected in some of the monitoring
wells on Dupont's site and the general public's concern over the
health effects of C8, the Fayetteville Regional Office of the Division
of Water Quality recommends a monitoring requirement only for C8
on the effluent for data collection and information purposes.
2. All discharges form this site ultimately go into the Woodlined Ditch,
which collectively discharges into an effluent channel that discharges
to the Cape Fear River. Over the years the flow of the effluent
through the channel has significantly eroded the banks and has
carried and deposited the sediment in the Cape Fear River forming a
Delta like structure. It is apparent from a meeting on March 10, 2006
with Mike Johnson, Environmental Manager for Dupont's
Fayetteville Works, that Dupont acknowledges 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
PART III- OTIIER PERTINENT INFORMATION -(continued)
effluent channel for some years and needs to address this issue soon. As
per a phone conversation with Mike Johnson it was understood that
stream studies were about to begin to determine the best place to relocate
the outfall line. This office requests that DuPont provide to Fayetteville
Regional Office of the Division of Water Quality a definite plan of action
(to be incorporated into this permit or other administrative mechanism) to
address this issue.
PART IV -EVALUATION AND RECOMMENDATIONS
It is the recommendation of the Fayetteville Regional Office that NPDES Permit No. NC0021636 be
issued for the wastewater treatment plant. The subject application for permit renewal should be processed
in keeping with basinwide strategy.
Sign Report Preparef
Lei 3 Yw� t%rL)
Water Quality Regional Supervisor
DuPont Company – Fayetteville Works
NPDES Permit No. NC0003573
Supplemental Information
Proposed Changes in Operations
PVF Manufacturing Facility: The DuPont Company –Fayetteville Works has been selected as
the location for the DuPontTM Polyvinyl Fluoride (PVF) manufacturing process. The
manufacturing facility is in the process of being designed, and will produce PVF polymer resins.
PVF resin to be manufactured at the Fayetteville plant is used in DuPontTM Tedlar®
fluoropolymer film business. Tedlar® film is manufactured at other DuPont site location (not
the Fayetteville plant). Tedlar® is used in the photovoltaic industry in photovoltaic cells and the
aircraft industry for interior cabin surfaces, as well as many other uses. This new facility
construction will be completed in August 2007 and begin start up in October 2007.
The manufacturing facility will be located near the existing Teflon® FEP resin manufacturing
area. This process will produce polyvinyl fluoride (PVF) resin (CAS No. 24981444).
As with most fluorochemical processes, the wastewater from the PVF manufacturing process is
expected to have very little or no biological oxygen demand (BODS) value. Treatability tests
have been performed on samples from another DuPont site which currently manufactures PVF.
These studies have indicated use of non -biological treatment will meet effluent limitation of
OCPSF NSPS guidelines of Subpart D—Thermoplastic Resins (40 CFR 414.40). DuPont
proposes to discharge the treated wastewaters from this new facility through a currently
permitted outfall, designated as Outfall 006. The contact process wastewater and stormwater
will be treated with solids separation technology prior to discharging to the outfall.
A suggested change to the language of the current permit's narrative for Outfa11006 that would
accommodate the new PVF Manufacturing Facility follows:
"Beginning on the effective date of this permit and lasting through the expiration date, the
Permittee is authorized to discharge from Outfa11006 (Polyvinyl fluoride Manufacturing
Facility low -biodegradable process wastewaters). Such discharges shall be limited and
monitored by the Permittee as specified below:"
The process wastewater is expected to contain unreacted vinyl fluoride (CAS No. 00075-02-5).
The anticipated quantity of vinyl fluoride from the PVF Manufacturing Facy is 0.312 pounds
per day. This quantity would equate to 0.9 mg/L vinyl fluoride at Outfall 006 and 0.0035 mg/L
vinyl fluoride at Outfall 002.
Finally, non -contact cooling, condensate, and stormwater from the PVF Manufacturi
ng Facility
will be discharged directly to Outfall 002 via the site's Woodlined Ditch.
DuPont Company — Fayetteville Works
Current Operating Conditions
NPDES Permit No. NC0003573
Supplemental Information
Butacite® Manufacturing: The DuPont Company — Fayetteville Works' Butacite®
manufacturing area produces two final products. DuPontTM Butacite® Interlayer plastic sheeting
is the final product used in safety glass such as automobile windshields. Polyvinyl butyral
(PVB) resin is shipped off-site as a transfer to other DuPont locations for final processing.
Wastewater generated from this manufacturing facility is treated in the site's biological
wastewater treatment plant (WWTP).
Nafion® Manufacturing: The DuPont Company — Fayetteville Works' Nafion®
manufacturing area produces five final products. DuPontTM Nafion® Membrane is a plastic film
used in the chloroalkali industry and in electrochemical fuel cells. Nafion® Resins are
ultimately extruded into a finished film. The FLPR Vinyl Ether and HFPO monomers are
shipped to other DuPont locations to produce various fluorochemical products such as DuPontTM
Teflon®. Wastewater generated from this manufacturing facility is neutralized and discharged to
the WWTP.
Teflon® Manufacturing: The DuPont Company —Fayetteville Works' PMDF Teflon®
manufacturing area produces DuPontTM Teflon® FEP resin. Teflon® FEP resin is used in the
electronics industry as a coating for wire, as well as many other uses. This facility was
constructed in 1999-2000 and was started up in December 2000. Wastewater generated from
this manufacturing facility is treated in the'WWTP.
APFO Manufacturing: The DuPont Company —Fayetteville Works' APFO manufacturing
area produces ammonium perfluorooctanoate. The APFO produced in this unit is used to
produce fluoropolymers and fluorinated telomers, but none of the produced APFO is used at the
Fayetteville Works site. This facility was started up in November 2002. All wastewater
9 r__ �1_.0 _---... r 'y. . r e1•: &44 . . _
SentryGlas® Plus Manufacturing: The DuPont Company —Fayetteville Works' SentryGlas®
Plus manufacturing area produces DuPontTM SentryGlas® Plus Tonoplast interlayer laminate.
SentryGlas® Plus interlayer is used for laminated safety glass in side, rear, and overhead
automobile windows. It is also used in architectural applications desiring safety glass. This
facility was started up in June 2005. There is no contact process wastewater generated from this
manufacturing facility, therefore only sanitary waste from this area is treated in the WWTP.
This manufacturing facility does discharge non -contact cooling water to the woodlined ditch and
ultimately to Outfall 002.
Ms. Teresa Rodriguez
NCDENR Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699 - 1617
SUBJECT: NPDES Permit Renewal Applicat��
Revised Form 2C and Supplemental
NPDES Permit No. NC0003573
Dear Ms. Rodriguez:
Addendum
on
DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
August 2, 2006
DE:NR •'h`ATE� QUAIIiY
i'rJ�? �Oi�RCE t36a;AC�CN
Enclosed are the revised Form 2C submittals for the subject renewal application. These
forms include the omitted analytical data. Outfall 002 sampling showed unexpected positive
results for cyanide, chloroform, dichlorobromomethane, and bis(2-ethylhexyl)phthalate; none of
which are used or produced at this site.
Also, you will find a revised Supplemental Information document that describes the
proposed changes with the construction of a new manufacturing unit that will produce Polyvinyl
Fluoride (PVF) polymer resins. It has been determined that the preferred means of controling
solids from the PVF unit is a new clarifier which will be dedicated to the PVF wastewater. The
discharge from this clarifier will be to the existing Outfall 001. Therefore, please ignore the
original submittal's description of the PVF treated wastewater being discharged through and
monitored at Outfa11006.
A revised water balance sheet is enclosed which reflects the above treatment change.
Should you have any questions, please feel free to call me at (9101 678-1155.
Enclosures
E.I. du Pont de Nemours and Company
Michael E. Johnson
Environmental Manager
DuPont Company – Fayetteville Works
NPDES Permit No. NC0003573
Supplemental Information (Revised)
Revised Supplemental Information – Permit Renewal Application – August 1, 2006
Prouosed Changes in Operations
PVF Manufacturing Facility: The DuPont Company – Fayetteville Works has been selected as
the location for the DuPontTM Polyvinyl Fluoride (PVF) manufacturing process. The
manufacturing facility is in the process of being designed, and will produce PVF polymer resins.
�. PVF resin to be manufactured at the Fayetteville plant is used in DuPontTM Tedlar®
fluoropolymer film business. Tedlar® film is manufactured at other DuPont site location (not
the Fayetteville plant). TedlarO is used in the photovoltaic industry in photovoltaic cells and the
aircraft industry for interior cabin surfaces, as well as many other uses. This new facility
construction will be completed in August 2007 and begin start up in October 2007.
The manufacturing facility will be located near the existing Teflon® FEP resin manufacturing
area. This process will produce polyvinyl fluoride (PVF) resin (CAS No. 24981-14-4).
As with most fluorochemical processes, the wastewater from the PVF manufacturing process is
expected to have very little or no biological oxygen demand (BODS) value. Treatability tests
have been performed on samples from another DuPont site which currently manufactures PVF.
These studies have indicated use of non -biological treatment will meet effluent limitation of
OCPSF NSPS guidelines of Subpart D—Thermoplastic Resins (40 CFR 414.40). DuPont will
control solids in the wastewater from this new facility via a new dedicated clarifier whose
,> discharge will go directly to Outfall 001.
A suggested change to the language of the current permit's narrative in the "Supplement To
Permit Cover Sheet" that would accommodate the new PVF Manufacturing Facility follows:
1. Continue to operate existing wastewater treatment facilities consisting of:
• equalization; (etc)
2. To operate new wastewater treatment facilities consisting of:
• clarifier for PVF process wastewater;
3. Discharge treated process wastewater from Butacite, Nafion, PVF, and Teflon® PMDF,
process stormwater, sanitary wastewater, and co -neutralized regenerate form said treated
facilities through internal outfall 001;
The process wastewater is expected to contain unreacted vinyl fluoride (CAS No. 00075-02-5).
The anticipated quantity of vinyl fluoride from the PVF Manufacturing Facility is 0.312 pounds
per day. This quantity would equate to approximately 0.04 mg/L vinyl fluoride at Outfall 001
and 0.0035 mg/L vinyl fluoride at Outfall 002.
Finally, non -contact cooling, condensate, and stormwater from the PVF Manufacturi
ng Facility
will be discharged directly to Outfa11002 via the site's Woodlined Ditch.